Is a defendant's technical knowledge relevant to an assessment of his knowing exercise of the right to defend himself?

A defendant's "technical legal knowledge, as such, [is] not relevant to an assessment of his knowing exercise of the right to defend himself." (Faretta v. California, supra, at p. 836.)

In Godinez v. Moran (1993) 509 U.S. 389, at page 399, the court held that "the competence that is required of a defendant seeking to waive his right to counsel is the competence to waive the right, not the competence to represent himself." (Original italics, fn. omitted.) Therefore, a finding that a defendant is competent to stand trial is also a finding that a defendant is competent to waive the right to counsel and assert the right of self-representation. (Id. at pp. 396-402.) The court stated that although there is no higher standard of competency for a defendant's waiver of counsel and assertion of the right to self-representation, "a determination that he is competent to stand trial is not enough; the waiver [of the right to counsel] must also be intelligent and voluntary before it can be accepted." (Id. at p. 402, fn. omitted.) The court noted: "The purpose of the 'knowing and voluntary' inquiry, by contrast, is to determine whether the defendant actually does understand the significance and consequences of a particular decision and whether the decision is uncoerced." (Id. at p. 401, fn. 12, original italics.)