Ella Mental is charged with burglary. Ella has only a grade school education, and she has been in and out of mental institutions for much of her life. Ella tells the judge that she wants to represent herself in the burglary case. The judge allows Ella to do so, on the ground that Ella has been convicted of various crimes three times in the past and is thus familiar enough with criminal law to represent herself. Ella goes to trial, and her questions to prosecution witnesses are garbled and for the most part ruled improper by the judge. Ella is convicted. Should she have been able to represent herself (why/why not)?

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