In the 1974 case of Faretta v. California, the United States Supreme Court ruled that a defendant in a state criminal trial has an independent constitutional right to represent himself when he voluntarily and intelligently elects to do so. Anthony Faretta was charged with grand theft in California and sought to represent himself at his own trial, but was denied by the court on grounds that he lacked legal skills or knowledge. The U.S Supreme Court overturned this decision, stating it violated his Sixth Amendment right which guarantees self-representation in criminal trials. However, they also noted that defendants who choose self-representation must be made aware of the risks associated with their decision.

In the dissenting opinion for Farettta v. California, Justice Blackmun argued that the majority's decision to allow defendants to represent themselves in court was misguided and could potentially undermine the integrity of criminal trials. He contended that while it is important to respect individual autonomy, this should not come at the expense of an orderly and reliable judicial process. The right to self-representation does not explicitly exist in the Constitution; rather, it has been inferred from other constitutional provisions by previous courts. Furthermore, he expressed concern about potential negative consequences such as increased trial length due to unskilled self-representation or a higher likelihood of reversible error on appeal because laypersons are unfamiliar with complex legal rules and procedures. Ultimately, he believed that ensuring fair trials through professional representation outweighed any perceived benefits from allowing defendants to represent themselves.