In that case, the court held that self-representation may not be denied to those defendants who knowingly, competently, and intelligently relinquish the benefits associated with the right to counsel; the defendant's wisdom in choosing to represent himself, or his lack of technical legal knowledge, is not relevant to the exercise of the right. However, the Faretta court left undecided the question of whether self-representation may be denied on the grounds that the defendant is mentally incompetent to represent himself. This author surveys pre- and post-Faretta case law, concluding that the accused cannot be allowed to represent himself unless mentally capable of presenting a minimally coherent defense. However, he recognizes that the due process standard of competence when an accused opts for self-representation would be different than when the accused has the assistance of counsel. 80 notes