The appellate court affirmed the district court’s grant of habeas relief where the denial of Van Lynn’s Faretta motion violated her Sixth Amendment rights. The trial court denied the motion based on the ground that Van Lynn was not competent to represent herself because she would be unable to present her case in an informed, reasonable, and intelligent manner. The correct standard under Godinez v. Moran is that to be competent to represent oneself, a defendant must have a rational understanding of the proceedings. The competence required is the competence to waive the right to counsel, not the competence to represent himself.