In 1975, the US Supreme Court formally recognized the idea that States could not force a defendant to accept a public defender. The issue thus becomes not whether a defendant may waive counsel, but who may waive counsel and under what circumstances. On one hand, defendants have a constitutional right to defend themselves. On the other hand, the state has an interest in protecting incompetents, juveniles, and the general public for whom presenting a case at trial would be tantamount to having no trial at all. The Note examines the Faretta v. California colloquy that the Constitution requires between the trial judge and the defendant to determine competency and inform defendants of their rights. The Note also discusses the evolution of the competency requirement necessary for waiver; analyzes whether juveniles may waive their right to counsel and explores the circumstances under which they may do so; and discusses some procedurally unusual and well-publicized cases and how judges handle them. Notes