the applicable standard of review, we describe how trial courts may consider a defendant's mental illness when applying the existing two-part framework for determining whether a defendant has validly waived the right to counsel. Then, we discuss why Colorado law does not require an additional competency standard for mentally ill defendants in light of Edwards. A. Standard of Review 114 We review questions of law, such as whether to adopt a new standard under Edwards, de novo. See Lucero v. People, 2012 CO 7, ¶ 19, 272 P.3d 1063, 1065. B. Waiver of the Right to Counsel 115 A criminal defendant bas a constitutional right to represent himself. U.S. Const. amends. VI, XIV; Colo. Const. art. II, § 16; Faretta v. California, 422 U.S. 806, 818-19, 95 S.Ct. 2525, 45 L.Ed.2d 562 (1975) (<HOLDING>). A defendant must validly waive his
holding that the sixth and fourteenth amendments imply the right to selfrepresentation holding that any confrontation right is found in the fourteenth amendments due process clause not the confrontation clause of the sixth amendment holding that the fourteenth amendment incorporated the sixth amendment right to counsel holding that it is wellsettled that the sixth and fourteenth amendments of the united states constitution guarantee a defendant on trial for his life the right to an impartial jury holding the sixth amendment right to a jury trial applies to the states through the fourteenth amendment