What is the test for waiver of the Sixth Amendment right to counsel?

MultiRegion, United States of America

The following excerpt is from Lopez v. Thompson, 202 F.3d 1110 (9th Cir. 2000):

Because the majority, while paying lip service to Faretta v. California, 422 U.S. 806 (1975), strips of all meaning its requirement that the waiver of the Sixth Amendment right to counsel must be "knowingly and intelligently" made, id. at 835, I respectfully dissent.

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