Appellant represented himself in a misdemeanor battery case. He was not admonished pursuant to Faretta v. California. The appellate division of the Superior Court affirmed, finding that the Faretta error was harmless because the case did not involve a sophisticated defense or complicated legal issues. After the state courts denied him relief, appellant filed a writ in federal court, which was granted. The government appealed. The appellate court here affirmed the grant of habeas relief. If a criminal defendant is put on trial without counsel, and his right to counsel has not effectively been waived, he is entitled to an automatic reversal of the conviction. The appellate division’s effort to analyze the evidence and determine what would have happened with counsel is precisely the kind of inquiry which cannot be made.