I. Whether, for a waiver of the Sixth Amendment right to trial counsel to be effective, a defendant must understand the elements of the charged offenses — as part of the defendant's understanding of the "nature of charges," Von Moltke v. Gillies, 332 U.S. 708, 724 (1948) (plurality op.)); cf. Bradshaw v. Stumpf, 545 U.S. 175, 183 (2005) ("Where a defendant pleads guilty to a crime without having been informed of the crime's elements, th[e] [due process] standard is not met and the plea is invalid.")

II. Whether a trial judge must provide unambiguous information about the maximum criminal penalties that a defendant faces upon conviction before accepting the defendant's waiver of her right to trial counsel.

III. Whether, when the record indicates that a criminal defendant has mental illness, a trial judge must make specific inquiries about the defendant's mental health history before accepting the defendant's waiver of her right to trial counsel.

IV. Whether a trial judge must address the factors set forth in the plurality opinion in Von Moltke, supra, in a waiver colloquy in order for a defendant's waiver of the Sixth Amendment right to counsel to be valid.

Whether a defendant must understand the elements of the charged offenses for a valid waiver of the Sixth Amendment right to trial counsel