People of Michigan v. Frank King

Summary

The Court held that a defendant who requests self-representation does not forfeit the constitutional right to counsel merely by failing to object when the trial court accepts an invalid waiver. Because the invalid waiver deprived defendant of counsel during multiple critical stages, the resulting structural error required automatic reversal, and the later no-contest plea did not cure the deprivation. Justice Viviano concurred dubitante, questioning whether the plea waived the earlier error and whether actively participating standby counsel could satisfy the right to counsel.