What is the test for having assigned counsel in a civil proceeding pro se?

MultiRegion, United States of America

The following excerpt is from United States v. Nina, No. 14-2187-cr (2nd Cir. 2015):

"the defendant understood that he had a choice between proceeding pro se [or] with assigned counsel, . . . understood the advantages of having one trained in the law to represent him, and . . . had the capacity to make an intelligent choice." United States v. Hurtado, 47 F.3d 577, 583 (2d Cir. 1995) (citations and internal quotation marks omitted).

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