UNDER THE BIFURCATED MODEL, A CRIMINAL DEFENDANT EITHER MAY DELEGATE TO HIS ATTORNEY FULL RESPONSIBILITY FOR CONDUCTING HIS TRIAL OR MAY APPEAR PRO SE, I.E., ACT AS HIS OWN ATTORNEY. COURTS HAVE ASSUMED THAT THE SIXTH AMENDMENT RIGHTS TO REPRESENTATION BY COUNSEL AND TO DEFENSE PRO SE ARE MUTUALLY EXCLUSIVE. UNDER THE HYBRID MODEL, THE DEFENDANT HAS THE ACTIVE ASSISTANCE OF COUNSEL BUT MAY ALSO PARTICIPATE IN HIS OWN DEFENSE AS CO-COUNSEL. THE HYBRID MODEL FOCUSES ON THE DEFENDANT AS THE PERSON WHO CONTROLS THE MODE OF HIS REPRESENTATION AND THE CONDUCT OF HIS DEFENSE. JUDICIAL DECISIONS RELEVANT TO THE BIFURCATED MODEL OF REPRESENTATION RIGHTS ARE REVIEWED, AND THE CONSTITUTIONAL BASIS OF THE RIGHT TO HYBRID REPRESENTATION IS ANALYZED. IT IS CONCLUDED THAT, UNLIKE THE BIFURCATED MODEL, THE HYBRID MODEL ACCOMMODATES THE FUNDAMENTAL VALUES UNDERLYING THE SIXTH AMENDMENT AND SHOULD BE RECOGNIZED AS THE 'CONSTITUTIONALLY COMPELLED APPROACH', FOR IMPLEMENTING THE RIGHT TO ASSISTANCE OF COUNSEL.