Someone who appears before the court "pro se" is doing what?

A Latin phrase meaning "for oneself," pro se (proh say) describes a party who is representing themselves without a lawyer. While the Sixth Amendment guarantees a criminal defendant the right to legal representation, the Supreme Court has ruled that the exercise of that right is not mandatory. Nonetheless, a court will not approve a defendant's waiver of the right to counsel unless it determines that the waiver is knowing, voluntary, and intelligent, which depends on "a range of case-specific factors, including the defendant's education or sophistication, the complex or easily grasped nature of the charge, and the stage of the proceeding."

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