What is the test for an unqualified guilty plea in a capital murder case?

As described more fully below, defendant sought to plead guilty to the capital murder charge and to admit a special circumstance allegation from the outset of the proceedings in March 2005. When his appointed counsel was unwilling to consent to a guilty plea, defendant asserted his right to represent himself. (See Faretta v. California (1975) 422 U.S. 806, 95 S.Ct. 2525, 45 L.Ed.2d 562 ( Faretta ).) The trial court granted defendants motion, and appointed advisory counsel to assist him. Advisory counsel reviewed all of the evidence with defendant, and eventually concluded that entering an unqualified guilty plea to the murder charge and admitting the special circumstance allegations was an intelligent tactic to try to avoid a death sentence.

[430 P.3d 856]