In what circumstances will a defendant waive his right to counsel in a criminal case?

counsel should not significantly increase the burden on the courts. While "the volume of misdemeanor cases, far greater in number than felony prosecutions, may create an obsession for speedy dispositions, regardless of the fairness of the result," we must continually guard against "assembly-line justice," in which expediency is placed ahead of fundamental fairness. Id. at 34, 35-36, 92 S.Ct. 2006. It is the duty of the courts to safeguard the fundamental right to liberty by ensuring that a defendant's waiver of the right to counsel is knowing and intelligent. See Johnson v. Zerbst, 304 U.S. at 465, 58 S.Ct. 1019.