Foster v. Tatum

(1) Whether the Supreme Court's case law "clearly establish[es]," 28 U.S.C. § 2254(d), that a defendant's waiver of counsel is "knowing and voluntary" even if the trial court finds that the defendant does not, in fact, understand the difficulties of self-representation; and (2) whether the Supreme Court's case law "clearly establish[es]," 28 U.S.C. § 2254(d), that a trial court must grant a defendant's request to represent himself at trial even if the defendant cannot carry out this representation "competently."