with whom Justice Brennan and Justice Marshall join, dissenting.
Just as the Sixth Amendment accords an accused a fundamental right to the assistance of counsel, so also, this Court has recognized, it embodies “the correlative right to dispense with a lawyer’s help,” Adams v. United States ex rel. McCann, 317 U. S. 269, 279 (1942), and to manage one’s own defense. Faretta v. California, 422 U. S. 806 (1975). It is, I believe, “undeniable that in most criminal prosecutions defendants could better defend with counsel’s guidance than by their own unskilled efforts.” Id., at 834. Nevertheless, “Faretta establishes that the right to counsel is more than a right to have one’s case presented competently and effectively.” Jones v. Barnes, 463 U. S. 745, 759 (1983) (Brennan, J., dissenting). “The right to defend is personal,” Faretta, 422 U. S., at 834, and the text and structure of the Sixth Amendment, as well as the common-law jurisprudence from which the Amendment emerged, comport with “a nearly universal conviction, on the part of our people as well as our courts, that forcing a lawyer upon an unwilling defendant is contrary to his basic right to defend himself if he truly wants to do so.” Id., at 817. Thus, an accused who knowingly, intelligently, and voluntarily elects to do so is constitutionally entitled to refuse the services of a *189government-appointed attorney and to develop and present his own defense. Id., at 835-836.
rH
After granting Wiggins’ request that he be allowed to represent himself, the trial court designated his two appointed attorneys as standby counsel and made it clear that they served in a purely advisory capacity. One of the attorneys soon began to assume a more active role in the proceedings, and Wiggins protested that counsel’s unsolicited participation was frustrating the conduct of his defense. The trial court informed Wiggins that he would receive counsel’s aid whether he wanted it or not,1 and it refused to instruct standby counsel not to volunteer their assistance without a request from Wiggins.2
*190Wiggins, on his own, made numerous pretrial motions, directly examined his own witnesses, cross-examined the State’s witnesses, and attempted to argue his case to the jury *191at both stages of the bifurcated trial. But the trial did not go smoothly, for standby counsel “continuously participated in the proceedings, both in and outside the presence of the jury.” Wiggins v. Estelle, 681 F. 2d 266, 269-270, rehearing denied, 691 F. 2d 213 (CA5 1982). In addition to making objections and motions too numerous to cite, counsel argued with Wiggins, moved for a mistrial against his wishes at several points during the trial, and twice cursed, once in the presence of the jury.
Although petitioner characterizes counsel’s participation as “limited” and “intermittent,” nothing could be further from the truth. Standby counsel intervened in a substantial manner without Wiggins’ permission well over 50 times during the course of the 3-day trial; many of these interruptions precipitated direct conflicts between Wiggins and counsel, often in the presence of the jury. See App. A-3 — A-54. Although the trial court appears to have resolved the conflicts calling for a ruling in Wiggins’ favor, their mere existence disrupted the proceedings and turned the trial into an ordeal through which the jury was required to suffer. See, e. g., id., at A-29; Record 423. At several points during the trial, moreover, counsel blatantly interfered with Wiggins’ attempt to present his defense in a manner not calling for a ruling from the bench, see, e. g., App. A-20, and we of course have no way of knowing the extent to which Wiggins’ defense was subtly undermined or adversely affected by counsel’s extensive unsolicited participation.
The Court of Appeals had little trouble concluding that counsel’s conduct, expressly and tacitly approved by the trial court, prevented Wiggins from conducting his own defense. Although the Court of Appeals recognized that trial courts are empowered to appoint standby counsel for pro se defendants, it declared that “court-appointed standby counsel is ‘to be seen, but not heard.’” 681 F. 2d, at 273. Standby counsel, the Fifth Circuit made clear, “is not to compete with the defendant or supersede his defense. Rather, his presence *192is . . . for advisory purposes only, to be used or not used as the defendant sees fit.” Ibid, (footnotes omitted).
The court recognized that in some cases counsel’s interjections will be “few and innocuous”; reversal is not necessary “every time overzealous counsel, acting in the best interests of his client, volunteer[s] his aid without prior permission.” Id., at 274. But the continuous and substantial intervention of standby counsel, despite Wiggins’ repeated demands that he play a passive role, could not have had “anything but a negative impact on the jury. It also destroyed Wiggins’ own perception that he was conducting Ms defense.” Id., at 275 (emphasis in original). The Court of Appeals thus held that the State had failed to demonstrate that Wiggins had not been prejudiced by counsel’s participation and that he was entitled to relief.
Disagreeing with the Court in several respects, I would affirm the judgment of the Court of Appeals.
HH hH
The Court holds that the seen-but-not-heard standard used by the Court of Appeals in determining whether standby counsel improperly encroached on Wiggins’ right of self-representation is too rigid and too restrictive on the conduct of standby counsel. As indicated above, however, the Court of Appeals would not hold that every instance of volunteered assistance or even every series of such instances would violate a defendant’s rights. Nor, as I understand it, would the Court of Appeals’ holding prevent a trial judge from directing a defendant to consult with standby counsel where necessary for the proper conduct of the trial or from insisting that a defendant agree to some ground rules with respect to when standby counsel could inject himself into the trial. I agree that the trial judge himself should not be burdened with educating the defendant in trial procedure and that he should be able to insist that the defendant learn what he needs to know *193from standby counsel. The judgment below is not to the contrary. In my view, the Court of Appeals announced a proper standard, one that is wholly consistent with Faretta’s ruling that “a State may — even over objection by the accused — appoint a ‘standby counsel’ to aid the accused if and when the accused requests help,” Faretta v. California, 422 U. S., at 835, n. 46, and applied it in an acceptable way. In any event, it seems to me that the Court proffers a poor substitute for the approach of the Court of Appeals.
I — I H — I
As the Court observes, ante, at 173, Faretta presented a situation in which the trial court wholly denied a defendant’s request to proceed pro se and required him to address the State’s charges only through his appointed attorney. Wiggins, unlike Faretta, was allowed to proceed pro se and took an active role in his trial. The Court concludes, on the basis of its examination of the record, that Wiggins was afforded “a fair chance to present his case in his own way,” ante, at 177, and that “counsel’s unsolicited involvement was held within reasonable limits,” ante, at 188. It arrives at this conclusion by applying a two-part test that, in my judgment, provides little or no guidance for counsel and trial judges, imposes difficult, if not impossible, burdens on appellate courts, and undoubtedly will lead to the swift erosion of defendants’ constitutional right to proceed pro se.
Under the Court’s new test, it is necessary to determine whether the pro se defendant retained “actual control over the case he [chose] to present to the jury,” ante, at 178, and whether standby counsel’s participation “destroyed] the jury’s perception that the defendant [was] representing himself,” ibid. Although this test purports to protect all of the values underlying our holding in Faretta, it is unclear whether it can achieve this result.
As long as the pro se defendant is allowed his say, the first prong of the Court’s test accords standby counsel at a bench *194trial or any proceeding outside the presence of a jury virtually untrammeled discretion to present any factual or legal argument to which the defendant does not object. The limits placed on counsel’s participation in this context by the “actual control” test are more apparent than real. First, counsel may not “make or substantially interfere with any significant tactical decisions.” Ibid. Unless counsel directly overrides a defendant’s strategy in the presence of the judge, however, it is apparent that courts will be almost wholly incapable of assessing the subtle and not-so-subtle effects of counsel’s participation on the defense. Second, the Court suggests that conflicts between the pro se defendant and standby counsel on “matter[s] that would normally be left to the defense’s discretion,” ante, at 181, will be resolved in the defendant’s favor. But many disagreements will not produce direct conflicts requiring a trial court to choose one position over another. Under the Court’s opinion, the burden apparently will fall on the pro se defendant to comprehend counsel’s submissions and to create conflicts for the trial court to resolve. If applied this way, the Court’s test surely will prove incapable of safeguarding the interest in individual autonomy from which the Faretta right derives.
Although the Court is more solicitous of a pro se defendant’s interests when standby counsel intervenes before a jury, the test’s second prong suffers from similar shortcomings. To the extent that trial and appellate courts can discern the point at which counsel’s unsolicited participation substantially undermines a pro se defendant’s appearance before the jury, a matter about which I harbor substantial doubts, their decisions will, to a certain extent, “affirm the accused’s individual dignity and autonomy.” Ante, at 178. But they will do so incompletely, for in focusing on how the jury views the defendant, the majority opinion ignores Faretta’s emphasis on the defendant’s own perception of the criminal justice system, Faretta v. California, supra, at 834, and implies that the Court actually adheres to the result-oriented harmless-error standard it purports to reject. Ante, at 177-178, n. 8.
*195As a guide for standby counsel and lower courts, moreover, the Court’s two-part test is clearly deficient. Instead of encouraging counsel to accept a limited role, the Court plainly invites them to participate despite their clients’ contrary instructions until the clients renew their objections and trial courts draw the line. Trial courts required to rule on pro se defendants’ objections to counsel’s intervention also are left at sea. They clearly must prevent standby counsel from overtly muzzling their pro se clients and resolve certain conflicts in defendants’ favor. But the Court’s opinion places few, if any, other clear limits on counsel’s uninvited participation; instead it requires trial courts to make numerous subjective judgments concerning the effect of counsel’s actions on defendants’ Faretta rights. Because trial courts generally will consider only isolated actions of standby counsel expressly challenged by pro se defendants, only appellate courts may be in a position to form impressions on the basis of the entire trial. These courts, however, also will suffer from the lack of clear standards and from their inability or unwillingness to make the factual inquiries necessitated by the Court’s two-part test.
In short, I believe that the Court’s test is unworkable and insufficiently protective of the fundamental interests we recognized in Faretta.
IV
The inappropriateness of the Court’s standard is made manifest by the Court’s conclusion that the conduct of standby counsel in this case passes muster under that standard. In frequently and grievously exceeding the proper role of standby counsel, the more active of Wiggins’ appointed attorneys distracted Wiggins and usurped his prerogatives,3 *196altered the tenor of the defense, disrupted the trial,4 undermined Wiggins’ perception that he controlled his own fate, Faretta v. California, 422 U. S., at 834, induced a belief— most assuredly unfounded, but sincerely held nevertheless— that “the law contrive[d] against him,” ibid.; see App. A-78—A-81; Record 679, 700-701, 716-717, and undoubtedly reduced Wiggins’ credibility and prejudiced him in the eyes of the jury. In allowing such intervention to continue despite Wiggins’ repeated requests that it cease, the trial court clearly denied Wiggins’ right of self-representation. The right to present and control one’s own defense means little indeed if one’s “standby” attorneys remain free to take any action they choose, whether consistent with the desired defense or inimical to it, at any point during the trial. In short, whatever advantage or satisfaction Wiggins might have hoped to derive from self-representation, see, e. g., ABA Standards for Criminal Justice 6-3.6(a) (2d ed. 1980), was surely nullified by the trial court’s tolerance of counsel’s conduct.
The Court reaches a different conclusion by pinning the blame for the interference with the right to proceed pro se on Wiggins himself and by dissecting counsel’s activities into discrete categories and failing to consider their overall impact. These tactics, of course, both required the Court to do its own factfinding, a function normally left for district courts. Neither approach can withstand scrutiny. Particu*197larly when the trial court has expressly refused to order standby counsel to serve in a purely advisory capacity, a pro se defendant cannot reasonably be expected to object to counsel’s every action. Not only would the trial court’s initial decision tend to impress upon the defendant the futility of continuing objections, but also repeated objections could destroy the impression the defendant seeks to convey to the jury. Accordingly, a defendant’s acquiescence in a violation of his Faretta right should not immunize that violation from judicial review. Similarly, the fact that a pro se defendant, with the trial court’s approval, has authorized standby counsel to perform a discrete representational function should not give rise to a presumption that the defendant also has sanctioned subsequent interference in the conduct of the trial. In any event, the most glaring intrusions by counsel occurred without Wiggins’ blessing.5
Considered in isolation, many types of interference by standby counsel in a pro se defense will likely appear inconsequential. The Court’s desire to compartmentalize counsel’s actions, while understandable, has, in my view, led it to ignore the cumulative effect of counsel’s frequent participation on Wiggins’ right to defend himself. To the extent that the Court rests on the proposition that not every transgression of standby counsel constitutes reversible error, I have no quarrel with its reasoning. A trial court’s tolerance of isolated and innocuous participation by standby counsel could perhaps be characterized — in line with the Court of Appeals’ holding — as harmless constitutional error; one also could conclude that such participation simply does not rise to the level of a constitutional violation. The second formulation is *198clearly preferable,6 but it is unnecessary to choose between them to resolve this case since Wiggins should prevail under either view.
V
It also seems to me that if a standard different from that applied by the Court of Appeals is to govern this case, the *199Court should be content with announcing it and remanding to the Court of Appeals for reconsideration in light of that standard, rather than itself undertaking to apply the new standard in the first instance. That course would more comport with the proper roles and functions of both this Court and the courts of appeals.
With all due respect, I dissent and would affirm the judgment of the Court of Appeals.
“DEFENDANT: Your Honor, I would like to defend myself. I would appreciate it, sir if you would ask this man to let me defend myself.
“MR. GRAHAM: Certainly. Help yourself.
“DEFENDANT: I would be grateful. I have not solicited his assistance, Your Honor, and I don’t want it.
“THE COURT: You are going to get help and/or assistance from him because you are obviously not a lawyer.
“DEFENDANT: Yes sir. I am not a lawyer.
“THE COURT: And this trial, if we do go into it, is going to be conducted according to the rules of law.
“DEFENDANT: Yes sir.
“THE COURT: And there might be an occasion when this Court is going to require that you consult with them as to what the proper procedure may be.
“DEFENDANT: Yes sir.
“THE COURT: You will have every right made available to you under the law, as this Court is able to determine.
“DEFENDANT: I appreciate that, Your Honor, but for assistant counsel to initiate something that the defendant does not want, I would like to consult the attorneys for advice. I will appreciate that, but for counsels [sic] to initiate something that is contrary to the defendant’s defense, well, then, I couldn’t appreciate that.” App. A-8 — A-9.
“THE COURT: You are waiving the ten days as far as Mr. Graham is concerned?
“THE DEFENDANT: Yes, Your Honor.
*190“THE COURT: The basis of that is that you expect to be an attorney for yourself pro se?
“DEFENDANT: Yes, Your Honor. In fact, not only that, I would like to waive his assistance, if I may.
“THE COURT: The Court is not going to relieve you of that. Now, you can use it or not use it. It’s available to you in this case.
“DEFENDANT: Yes sir, but I would ask the court to ask Mr. Graham not to take the initiative to interfere with the defendant here, if I may do that?
“THE COURT: Well—
“DEFENDANT: I mean, if I want Mr. Graham’s help I will ask for it and appreciate it if he wouldn’t volunteer without me asking for it.
“THE COURT: Well, Mr. Graham is a competent attorney and he has much experience in this type of thing and I am sure what he is trying to do is what he thinks is best for you. I am not going to order him to do or not to do anything. If some problem or situation arises, I will act on it at that time. I am not going to order him not to.
“DEFENDANT: Your Honor, do I understand that the Court is forcing the services of Mr. Graham on the defendant?
“THE COURT: His availability, yes.
“DEFENDANT: May I except to that, Your Honor?” Id,., at A-13— A-14.
After numerous disagreements between Wiggins and counsel, Wiggins was again moved to request the assistance of the trial court:
“DEFENDANT: May I say it is peculiar to me, Your Honor and I would really appreciate it if I could . . . conduct my defense without the assistance and interruptions of counsel, with all respect, Mr. Graham.
“THE COURT: All right.
“MR. GRAHAM: I will sit third chair from now on. I will move back one notch.
“THE COURT: I am not going to order you Mr. Graham, because I know you are competent counsel, but let me suggest to you that unless he consults with you — you do your own thing anyway, but don’t object or don’t ask questions unless and until the Court requests that you consult with him because he doesn’t know the proper way to do something.” Id., at A-30 — A-31. See also Record 345-346.
Notwithstanding this admonition, counsel continued to act of his own accord and to disrupt the presentation of Wiggins’ defense throughout the trial.
As has been cogently observed in a related context:
“[N]umerous strategic and tactical decisions must be made in the course of a criminal trial, many of which are made in circumstances that do not allow extended, if any, consultation. Every experienced advocate can recall the disconcerting experience of trying to conduct the examination of a witness *196or follow opposing arguments or the judge’s charge while the client ‘plucks at the attorney’s sleeve’ offering gratuitous suggestions.” ABA Standards for Criminal Justice 4-5.2 (2d ed. 1980).
Among other things, standby counsel’s actions created a need for numerous conferences out of the hearing of the jury. The disruptive, vexatious, and possibly prejudicial effects of repeated bench conferences have long been recognized, id., 15-3.9, and indeed were expressly acknowledged by the trial court. See, e. g., Record 423. The Court’s attempt to attribute many of these interruptions solely to Wiggins’ conduct is unpersuasive.
Although the Court attributes counsel’s extensive participation in the penalty phase of the trial to a conclusion by Wiggins that appearing pro se was not in his best interests, an equally plausible assumption is that Wiggins simply gave up his attempted self-representation as a result of the trial court’s approval of counsel’s repeated interruptions in the guilt phase.
“The nature of the right to defend pro se renders the traditional harmless error doctrine peculiarly inapposite. Unlike other constitutional rights, the right to represent oneself is not ‘result-oriented.’ The normal operation of the harmless error doctrine is in cases where the challenged error concerns a right accorded the defendant to facilitate his defense or to insulate him from suspect evidence. ... By contrast, we recognize the defendant’s right to defend pro se not primarily out of the belief that he thereby stands a better chance of winning his case, but rather out of deference to the axiomatic notion that each person is ultimately responsible for choosing his own fate, including his position before the law. A defendant has the moral right to stand alone in his hour of trial and to embrace the consequences of that course of action.” Chapman v. United States, 553 F. 2d 886, 891 (CA5 1977) (footnote omitted).
See Moreno v. Estelle, 717 F. 2d 171, 173, n. 1 (CA5 1983); Bittaker v. Enomoto, 587 F. 2d 400, 402-403 (CA9 1978), cert. denied, 441 U. S. 913 (1979); United States v. Dougherty, 154 U. S. App. D. C. 76, 90-93, 473 F. 2d 1113, 1127-1130 (1972); United States v. Plattner, 330 F. 2d 271, 273 (CA2 1964); People v. Tyner, 76 Cal. App. 3d 352, 356, 143 Cal. Rptr. 52, 54 (1977). But see People v. Sharp, 7 Cal. 3d 448, 462-463, 499 P. 2d 489, 498 (1972), cert. denied, 410 U. S. 944 (1973); Burney v. State, 244 Ga. 33, 37, 257 S. E. 2d 543, 547, cert. denied, 444 U. S. 970 (1979); State v. Kirby, 198 Neb. 646, 648-649, 254 N. W. 2d 424, 426 (1977). See also Walker v. Loggins, 608 F. 2d 731, 736 (CA9 1979) (Carter, J., dissenting).
As is the case when the trial court completely denies a defendant’s right of self-representation, application of the result-oriented harmless-error standard to cases like this one, where the defendant was allowed to proceed pro se but the conduct of his appointed standby counsel inhibited his ability to do so, would result in the denigration of the right. If counsel’s interference can be characterized as de minimis, it is more consistent with the nature of the right of self-representation to conclude that no violation occurred than to say that the violation was harmless constitutional error. If, as is the case here, counsel acted with substantial autonomy and significantly interfered with the pro se defendant’s presentation of his defense, reversal should follow automatically without any inquiry into the question whether the constitutional violation likely affected the outcome of the trial.