Should courts have to clearly define, on the record, the proper role of standby counsel in the proceedings? In other words, should courts engage in a colloquy with pro se defendants and counsel in order to establish the proper role of standby counsel for the defendant and counsel, thereby, protecting defendants' Sixth Amendment right to self-representation? Further, did this issue warrant the issuance of a Certificate of Appealability?

Should courts have to clearly define, on the record, the proper role of standby counsel in the proceedings?