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“Evidence of the defendant’s irrational behavior, demeanor at trial, and any prior medical opinion on competence to stand trial are relevant in determining whether there is reason to doubt the defendant’ s competence.” State v. Camacho

himself.” A defendant’s request for another attorney before choosing self-re presentation “will not by itself undermine the knowing, voluntary, and intelligent nature of the defendant’s waiver of counsel,” particularly when the defendant “is aware that he has no right to a different attorney and must proceed pro se upon rejection of the appointed attorney ’s assistance.”

“The Sixth and Fourteenth Amendments guarantee a criminal defendant the right to counsel.” State v. Camacho

the right to counsel at all critical stag es of the criminal process.” (quotation omitted)); United States v. Conklin, 835 F.3d 800, 804 (8th Cir. 2016) 5 (describing right of self-representation as “alternative” to right to counsel); (des cribing right of self-representation as “reciprocal[]” to right to counsel).

Additionally, a “defendant’s competence also plays a role in the defendant’s ability to waive the right to counsel.”

Mother raises two challenges to the district court’s decision to discharge her second attorney, for the premise that heightened scrutiny is required when someone with a diminished IQ waives the right to counsel.

The denial of the right to counsel “is a structural error,” Bonga, d at 643, that “does not require a showing of prejudice to obtain reversal.”

Drope v. Missouri, 420 U.S. 162, 171, 95 S. Ct. 896, 903 (1975)

The denial of the right to counsel “is a structural error,” that “does not require a showing of prejudice to obtain reversal.”

“[T]o determine whether a waiver of counsel is knowing and intelligent, a court should comprehensively examine the defendant regarding the defendant’s comprehension of the charges, the possible punishments, mitigating circumstances, and any other facts relevant to the defendant’s understanding of the consequences of the waiver.”

In considering whether there is reason to doubt a defendant’s competency, the district court is to consider several factors, including “[e]vidence of the defendant’s irrational behavior, demeanor at trial, and any prior medical opinion on competence to stand trial.”

DECISION I. “A defendant is denied the right to a fair trial under the Due Process Clause if the district court fails to observe adequate procedures to protect the defendant’s right not to be tried or convicted while incompetent.” see U.S. Const. amend XIV, § 1; Minn. Const. art. I, § 7; see also Drope v. 4 Missouri, 420 U.S. 162, 172, 95 S. Ct. 896, 904 (1975)

In considering whether there is reason to doubt a defendant’s competency, the court should consider factors such as “[e]vidence of the defendant’s irrational behavior, demeanor at trial, and any prior medical opinion on competence to stand trial.”

The denial of the right to counsel “is a structural error,” that “does not require a showing of prejudice to obtain reversal,”

to ensure a knowing, intelligent, and voluntary waiver-of-counsel, district courts “ ‘should comprehensively examine the defendant regarding the defendant’s comprehension of the charges, the possible punishments, *886 mitigating circumstances, and any other facts relevant to the defendant’s understanding of the consequences of the waiver.’ ” 6 Worthy, d at 276 ().

836 , 15 L.Ed.2d 815 (1966); State v. Bauer, 310 Minn. 103, 114 , -55 (1976).

The State meets its burden of proving a knowing, intelligent, voluntary waiver of Miranda rights if it shows the “Miranda warnings were given and that the individual stated that he or she understood those rights and then gave a statement.”

2525 , 45 L.Ed.2d 562 (1975)