What is the standard for using the phrase "farce and mockery" in the context of a civil case?

Further, the Ibarra standard is vague and subjective. As described by one federal court of appeals, "The phrase 'farce and mockery' has no obvious intrinsic meaning. What may appear a 'farce' to one court may seem a humdrum proceeding to another. The meaning of the Sixth Amendment does not, of course, vary with the sensibilities and subjective judgments of various courts. The law demands objective explanation, so as to ensure the even dispensation of justice." (Beasley v. United States, supra, 491 F.2d at p. 692.) ¹³