has not waived the requirement that the district court exercise discretion. More important, even if the district court does not consider the possibility of denying the motion for self-representation, the court is obliged to assure that the defendant’s waiver of counsel is knowing, voluntary, and intelligent. State v. Worthy, 583 N.W.2d 270, 276 (Minn.1998); Minn. R. Crim P. 5.02, subd. 1(4). And, where a defendant seeks substitute counsel on the basis of a claim that his present counsel is ineffective, a defendant’s waiver of counsel may not be voluntary where the court narrows the defendant’s options to either self-representation or proceeding with his present counsel. See, e.g., Pazden v. Maurer, 424 F.3d 303, 313 (3d Cir.2005); Gilbert v. Lockhart, 930 F.2d 1356, 1360 (8th Cir.1991) (<HOLDING>). At the very least, the court was required to
holding that defendants failure to obtain counsel despite opportunities to do so implied a waiver of counsel holding that a defendants decision to proceed pro se was voluntary despite having to choose between that course and proceeding with counsel with whom he had expressed dissatisfaction because the defendant had not shown good cause for substitution of counsel holding that a defendants waiver was invalid where he was required to choose between proceeding with unprepared counsel or no counsel holding that where trial counsel was not ineffective appellate counsel was not ineffective for failing to raise claim of ineffectiveness of trial counsel holding waiver of right to counsel at sentencing not voluntary when trial court tried to dissuade discharge of counsel defendant believed incompetent for the waiver to be voluntary the trial court must inquire into the reasons for the defendants dissatisfaction with his counsel to ensure that the defendant is not exercising a choice between incompetent or unprepared counsel and appearing pro se