Here's an interesting new Ninth Circuit case on the right to self-represent, US v. Johnson. The trial judge conducted a Faretta hearing and "practically begged [the defendants] to accept counsel but they refused." The court added, a bit harshly if accurately, "The record clearly shows that the defendants are fools, but that is not the same as being incompetent." The case also considered and rejected defendants' argument that the trial judge should have recused himself because of what he learned and what he ruled in a related civil case.