An accused who voluntarily dismisses competent counsel mid-trial is in a materially different position from the indigent accused in Dietrich; the 'exceptional circumstances' test for proceeding without representation does not apply in the same way. Even where a trial is unfair to an unrepresented accused, the conviction will only be set aside if the accused lost a real chance of acquittal. A sentencing judge must not treat as established a factual finding that was not necessarily made by the jury in reaching its verdict, and must not rely on aggravating factors not raised by the prosecution without giving the accused an opportunity to be heard.
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