People v. Adkins , 452 Mich. 702 ( 1996 )

Boyle, J.

(concurring). I am in complete agreement with the majority’s thoughtful and well-reasoned opinion. I write separately only to add that the substantial-compliance test, as phrased by the majority, is merely one method of determining that a defendant’s waiver of the right to counsel was knowing and voluntary. If the record illustrates that a defendant “made his decision to proceed pro se ‘with eyes open[,]’ ” the voluntary and knowing standard has been fulfilled and the waiver is valid. People v Den-nany, 445 Mich 412, 462; 519 NW2d 128 (1994) (Boyle, J., concurring), quoting Faretta v California, 422 US 806, 835; 95 S Ct 2525; 45 L Ed 2d 562 (1975). See People v Anderson, 398 Mich 361; 247 NW2d 857 (1976).

Riley, J., concurred with Boyle, J.