THE COURT, HOWEVER, REQUIRED THAT WAIVER OF THE RIGHT TO COUNSEL HAD TO BE MADE KNOWINGLY, INTELLIGENTLY, AND VOLUNTARILY. THIS CASE NOTE DISCUSSES THE HISTORICAL ROLE OF SELF-REPRESENTATION AND PRIOR CASE LAW AS TO ITS STATUS AS A CONSTITUTIONAL RIGHT. THE AUTHOR SUGGESTS THAT IN RECOGNIZING A CONSTITUTIONAL RIGHT OF SELF-REPRESENTATION, THE SUPREME COURT LEAVES MUCH TO SPECULATION AS TO ITS PRACTICAL IMPLEMENTATION AND OVERALL EFFECT UPON THE QUALITY OF JUSTICE TO BE ACHIEVED WHERE SUCH RIGHT IS ASSERTED.