What is the test for making an effective waiver of the Sixth Amendment?

The majority relies on United States v. Garcia (5th Cir. 1975) 517 F.2d 272 in its evaluation of whether Noday made an effective waiver. In that case, the court of appeals held that the trial court "... should address each defendant personally and forthrightly advise him of the potential dangers of representation by counsel with a conflict of interest," and "(m)ost significantly, the court should seek to elicit a [125 Cal.App.3d 525] narrative response from each defendant that he has been advised of his right to effective representation, that he understands the details of his attorney's possible conflict of interest and the potential perils of such a conflict, that he has discussed the matter with his attorney or if he wishes with outside counsel, and that he voluntarily waives his Sixth Amendment protections. (Citation.)" (Id., at p. 278, emphasis provided.)