Is a federal judge required to conduct a thorough pretrial examination of a defendant's waiver of counsel?

Such a rigorous pretrial inquiry is fully consistent with federal practice under the Sixth Amendment. Thus, for example, in Von Moltke v. Gillies (1948) 332 U.S. 708, 68 S.Ct. 316, 92 L.Ed. 309, Justice Black declared that a judge inquiring into the validity of a defendant's waiver of counsel "must investigate as long and as thoroughly as the circumstances of the case before him demand. ... A judge can make certain that an accused's professed waiver of counsel is understandingly and wisely made only from a penetrating and comprehensive examination of all the circumstances under

Page 71