dissenting.
I respectfully dissent from the majority’s view of this case because the trial judge forced the defendant to proceed to trial pro se in violation of his Sixth Amendment right to counsel purely because he had previously waived counsel. This was improper as a matter of law.
It is undisputed that Daniel Leveto knowingly and voluntarily waived his right to counsel on June 7, 2004, and that, at that time, a thorough colloquy was conducted. It is also undisputed that, as the majority notes, a defendant’s Sixth Amendment right to have counsel, once waived, is not absolute. A defendant who has waived the right to counsel, however, ordinarily may reassert it at any time pri- or to trial. See Menefield v. Borg, 881 F.2d 696 (9th Cir.1989) (noting that a defendant’s decision to represent him-or herself is not “cast in stone”).
Here, the defendant permissibly sought to reinvoke his right to counsel and withdraw his waiver prior to trial. The trial judge would not permit him to do so, and did not inquire as to his reasons for invoking counsel, or make the findings that we require in order to justify such a denial— namely that the request for counsel was an “apparent effort to delay or disrupt proceedings.” See United States v. Proctor 166 F.3d 396, 402 (1st Cir.1999); United States v. Merchant, 992 F.2d 1091, 1095 (10th Cir.1993). Instead, he summarily denied Leveto’s request for counsel because it was “a bit too late.” App. 312. In so doing, the trial judge erred and violated Leveto’s constitutionally protected right to counsel. I believe Leveto is entitled to a new trial and, therefore, dissent.
I. Standard of review and legal standard
As an initial matter, the majority opinion reasons as if we were reviewing a district court’s denial of a motion to substitute counsel, applying an abuse of discretion standard. However, our Court has made clear that “[w]e exercise plenary review over claims alleging denial of the Sixth Amendment right to counsel.” United States v. Goldberg, 67 F.3d 1092, 1097 (3d Cir.1995); United States v. Leggett, 162 F.3d 237, 249 (3d Cir.1998).10 Thus, our inquiry is to be more searching.
*213We are guided by the principle that “it is representation by counsel that is the standard, not the exception.” Martinez v. Court of Appeal, 528 U.S. 152, 161, 120 S.Ct. 684, 145 L.Ed.2d 597 (2000); see also Chapman v. California, 386 U.S. 18, 23 & n. 8, 87 S.Ct. 824, 17 L.Ed.2d 705 (1967) (clarifying that right to counsel is so fundamental to our adversarial system that its deprivation can never be held harmless); Fischetti v. Johnson, 384 F.3d 140, 147 (3d Cir.2004) (noting that, as between the right to self-representation and the right to counsel, right to counsel “is the presumptive default position”). We must, therefore, be “reluctant to deny the practical fulfillment of the right — even once waived — absent a compelling reason that will survive constitutional scrutiny.” Menefield, 881 F.2d at 700.
It is established that the denial of a request for counsel, following a waiver, is only proper “if a defendant seeks counsel in an apparent effort to delay or disrupt proceedings on the eve of trial,” Proctor 166 F.3d at 402, or “after meaningful trial proceedings have begun,” Merchant, 992 F.2d at 1095. The majority opinion fails to employ this standard.11
11. Leveto’s Request for Counsel and his Sixth Amendment Right to Counsel
The record shows that the trial judge denied Leveto’s request for counsel before trial proceedings had begun and without any indication that the request was an apparent effort to delay or disrupt proceedings, or indeed that any delay would result at all.
A. Before “meaningful trial proceedings” had begun
Neither the government nor the majority contends that “meaningful trial proceedings” had begun. The majority casts this portion of the legal standard as a “useless exercise here” that would require us needlessly to “parse” the proceedings. It is clear, however, that Leveto attempted to reinvoke his right to counsel prior to trial and jury selection, before any trial proceedings, let alone “meaningful” ones. Leveto’s case is therefore not like cases such as United States v. Tolliver, where the defendant did not request counsel until the trial was at its mid-point.12 937 F.2d *2141183, 1188-89 (7th Cir.1991); see also Merchant, 992 F.2d at 1095 (holding that where the defendant requested that his standby counsel take over the defense in the middle of the trial, while a witness was on the stand, and standby counsel requested a continuance, the trial court could properly deny the motion). The timing of Leveto’s request here does not support the denial of his request for counsel.
Therefore, the District Court could only deny Leveto’s request for counsel if it was an “apparent effort to delay or disrupt proceedings on the eve of trial.”
B. “Apparent Effort to Delay or Disrupt Proceedings on the Eve of Trial”
Although the majority’s opinion could be read as deciding that Leveto’s request for counsel was an apparent effort to delay proceedings, reaching this conclusion requires reading into the record some facts and considerations that simply are not there. The trial judge did not state that he was rejecting Leveto’s request out of concern for delay, travel of attorneys, or any of the other reasons the majority opinion ascribes to his denial of the request. Instead, he never even considered the request, but seemed to hold that once counsel is waived, a defendant cannot change his mind.
The record shows only the trial judge’s continued insistence that Leveto waived counsel before, had lost the opportunity to request counsel, and could not change his mind when the case was going to trial. In response to Leveto’s request for counsel prior to trial, referring to standby counsel, the judge said, “we appointed, Mr. Misko counsel a long, long time ago. You have been represented by counsel, but you didn’t want to take advantage of it.” App. 312 (emphasis added). When Leveto immediately renewed his request because, he said, “I believe that I no longer feel comfortable pro se and I do need to be represented by an attorney,” id., the judge replied, “[w]ell, this is a bit late to be asking that, so the motion is denied.” Id. (emphasis added). At the beginning of trial, Leveto again said, “I really believed that I could represent myself, but I seem to be having difficulties and mental blocks, and I am asking you again to have an attorney represent me.” App. 320. The judge again focused on the passage of time: “I’ve already ruled that you have had back-up counsel for some time and it’s a little late to be asking for more counsel now.” Id. (emphasis added). Mid-way through trial, the judge demonstrated his misunderstanding of Leveto’s right to reassert his right to counsel. After instructing Leveto that, “[tjhere will be no more talk about not having a lawyer. You waived that clearly in June of 2004,” App. 338, he added “you can’t relinquish it [the waiver of counsel] the day of trial.” App. 358 (emphasis added). There is no caselaw that supports the trial court’s intransigence in the face of a defendant’s assertion of the right to counsel.
There is no evidence of a purpose that would justify the court’s refusal here— namely to delay or disrupt trial. While the trial court may have understandably viewed the request skeptically and not have been favorably inclined toward Leveto' — who had sued him — nonetheless, a defendant’s request not to be forced to proceed through a complex trial representing himself requires an objective assessment of the situation. From that perspective, Leveto’s earlier decision that he did not need counsel was based on his view— *215shared by all, apparently, at the time— that the matter would proceed to a negotiated guilty plea. At the status conference on October 20, 2004, Leveto indicated that he would be announcing his intentions with regard to a possible plea after the suppression hearing scheduled for October 25th. He said, “it’s been no secret, but evidently it’s got to be official and on the record, I will not go to trial with this case.” App. 231; App. 233 (“I can tell you unequivocally that I will not be going to trial.”).
Any delays in the plea negotiations were caused equally, if not more so, by the government. The government noted that it had been involved in plea negotiations with Leveto and that, if they were to reach an agreement on Monday, the trial would have to be postponed from Tuesday morning because approval from the Department of Justice, and possibly the United States Attorney, would be necessary. Having said “[i]t doesn’t sound like we are going to have a trial, as a practical matter,” the judge postponed the suppression hearing to October 28th in order to move plea negotiations along and did not set a new trial date. App. 232, 239. On November 8, 2004, another status conference took place. The Court then continued the case for additional plea discussions and requested an answer as to a plea bargain by November 22nd.
Throughout these proceedings, Leveto continually indicated his willingness to plead and was most concerned that the plea be conditional so that he could appeal the denial of his motion to suppress. Although he initially wanted to plead nolo contendere, at one point Leveto offered to enter a conditional guilty plea to all charges, but the government refused to accept the plea unless he entered into a plea agreement waiving sentencing rights under Blakely v. Washington, 542 U.S. 296, 124 S.Ct. 2531, 159 L.Ed.2d 403 (2004). Plea negotiations ultimately broke down and the case continued to trial. Leveto had never requested a continuance or attempted to delay trial in any way; nor was it in his interest to do so as he was, and had been, incarcerated pending trial. Moreover, there is no indication that the government was any less responsible for delays caused by these proceedings. In fact, the judge seemed to believe just the opposite.13 Leveto had not vacillated regarding his need for counsel, as is so often the case in this type of situation.
In order to justify the denial of a request to reinvoke the right to counsel, there typically must be a manipulation or attempt to delay by abuse of the right to counsel. See Proctor, 166 F.3d at 402 (collecting cases). Leveto was not a defendant who had toyed with his right to counsel, hiring and firing attorneys or requesting continuances in order to substitute counsel. Bather, his initial attempts to secure counsel prior to his waiver were repeatedly thwarted.14 After all of his *216previous attorneys had proven to have conflicts, Leveto met with Stephen Misko on June 7, 2004 and determined that he wished to proceed pro se with Misko as standby counsel. Misko remained standby counsel throughout all proceedings. The only evidence of “abuse” of the right to counsel in this case would be that Leveto first waived his right to proceed pro se and then wanted to withdraw that waiver after plea negotiations failed.
The majority relies on the civil action filed by Leveto and his motion to recuse as obstructive conduct. However, they are not relevant to his right to counsel, as they are not examples of “the tension caused when a criminal defendant appears to be manipulating his right to counsel in order to delay his trial.” Goldberg, 67 F.3d at 1094; Fischetti, 384 F.3d at 145 (discussing defendant’s “pattern of uncooperative conduct through which [he] ... repeatedly complained about counsel and sought to delay or derail his second trial”). Indeed, at trial, when Leveto mentioned the civil action, the District Court acknowledged that the civil action “[has] got nothing to do with this case. That’s a separate matter.” App. 341. There is no indication that Leveto filed the action in bad faith. Rather, he believed that the judge’s extension of the government’s time to answer his pretrial motions, after the time for reply had expired, without requiring the government to show excusable neglect was a violation of Local Criminal Rule 12.1(c) and Federal Rule of Criminal Procedure 45(b)(1)(B) and showed the judge’s partiality toward the government. Though without merit, Leveto’s § 1983 action and the related recusal motion seem to have been designed to protect his constitutional rights rather than delay trial.15
Indeed, Leveto had some reason to believe that he was being unjustly treated. When he filed a previous civil action challenging the constitutionality of the method of execution of the search warrant at issue here, the District Court found no violation of his constitutional rights, Leveto v. Lapina, No. 98-143, 2000 WL 331902 (W.D.Pa. Feb.5, 2000). On appeal to our Court, however, we disagreed and held that the agents had violated his rights by detaining him for a lengthy period of time and patting him down during the search. Leveto v. Lapina, 258 F.3d 156 (3d Cir.2001) (Alito, J., writing for the Court, found that IRS agents had violated Leveto’s Fourth Amendment rights but had qualified immunity).
At the time he requested counsel, Leveto clearly found himself at a loss, representing himself at a trial that he (and perhaps even the District Court) had not anticipated. Losing the pretrial motions he thought were dispositive, as well as the recusal motion, made manifest his need for counsel in order to mount a defense and make viable legal arguments. It is reasonable to conclude that, having both sued and unsuccessfully moved to recuse the trial judge, Leveto believed that it would be wise to have an attorney represent him. Although the denial of his recusal motion undoubtedly played some role in his request for counsel, it did not represent an abuse of the right to counsel that justified denial of counsel or would have caused a delay.
*217In fact, there is no evidence in the record that the Court feared a delay, or that granting Leveto’s request for counsel would have resulted in any delay at all.16 Neither Leveto nor his standby counsel made a request for a continuance. Nor can we assume that one would have been necessary. In the absence of any record support, we cannot engage in conjecture that Misko — Leveto’s standby counsel who had followed all the proceedings and was present — would not have been able to step in as counsel immediately. In fact, inherent in the role of standby counsel is that he or she “must be ready to step in if the accused wishes to terminate his own representation.” United States v. Bertoli, 994 F.2d 1002, 1018-19 (3d Cir.1993); see also Anne Bowen Poulin, The Role of Standby Counsel in Criminal Cases, 75 N.Y.U. L.Rev. 676, 708-09 (2000). Misko had been standby counsel for almost a year, participated in pretrial conferences, received discovery, attended the suppression hearing, and arranged his schedule to be present at trial and available should Leveto require assistance in his defense.
Even if Misko had indicated he was unprepared and needed a continuance, the Court could have properly denied the request for a continuance and given Leveto the choice between proceeding pro se or proceeding with Misko, even though he was unprepared.
United States v. Pollani is instructive. 146 F.3d 269 (5th Cir.1998).17 In that particular case, the defendant had hired two lawyers while also filing many pro se motions, including one requesting that his lawyer be held in contempt. Id. at 270. He indicated he wanted to proceed pro se but would be retaining new counsel and was warned that he should do so immediately because the trial would not be continued. Id. He continued pro se, but, four days prior to trial, his new lawyer (Mr. *218Snow) requested he be substituted as counsel and granted a continuance to prepare for trial in a case with which he was unfamiliar. Id. at 271. The court denied the request for a continuance and then precluded Snow from representing Pollani because Pollani “had made a ‘knowing decision’ to represent himself, and an eleventh-hour substitution of counsel would not be permitted”; the lawyer was appointed standby counsel instead. Id. The Court of Appeals for the Fifth Circuit reversed and ordered a new trial. It reasoned that, although the trial court did not abuse its discretion by denying defendant’s request for a continuance, it had violated his right to counsel by refusing to allow the attorney, whom he had retained and who was available, to represent defendant at trial. While recognizing that “[i]t is true enough that Pollani was vigorously attempting to delay the start of the trial,” the Court reasoned:
This case is unlike other cases in which the district court declined to allow substitution of retained counsel for appointed counsel at the last minute, when to do so would require a continuance and delay the start of trial. See United States v. Silva, 611 F.2d 78, 79 (5th Cir.1980). This case is also unlike cases in which the district court denied a continuance that would be necessary for a defendant to be represented by particular counsel of his choice who was retained at the last minute. See, e.g., Neal v. Texas, 870 F.2d 312, 315 (5th Cir.1989). Those cases were decided on the basis of an appropriate denial of a continuance. They are distinguishable because in those cases the defendant was only deprived of exercising the right to counsel in a particular way which would unjustifiably delay the trial process. Had Pollani been seeking appointed counsel four days before the trial was to begin, the district court could have denied the request-there was not enough time to appoint counsel at that late date. Had Pollani been seeking a delay because his retained counsel had a conflict, the district court could deny the request-Pollani waited too long to appoint counsel, and he would have known the trial date when he hired his lawyer. As we have already explained, the district court in this case was entirely justified in denying a continuance in light of Pollani’s purpose of delay and the explicit warning that a continuance would not be granted in the event that Pollani waited too long to retain counsel.
The justifications for proceeding on schedule do not, however, justify the district court’s refusal to allow Snow to participate. This ease is different because Pollani had arranged to be represented by counsel instead of representing himself, and no delay was required for Pollani to exercise his right to do that.... The Constitution protects Pollani’s right to counsel under these circumstances, and the district court erred in disallowing Snow to represent Pollani at trial.
Id. at 273-74. Like the defendant in Pollani, Leveto was deprived of his Sixth Amendment counsel when the District Court denied his request to proceed with counsel.
III. The District Court erred in failing to develop the record as to the defendant’s attempted revocation of waiver
The District Court committed reversible error by failing to address the proper considerations in connection with Leveto’s request. The judge did not develop the record or inquire of Leveto in an attempt to respect his Sixth Amendment right. Nor did he balance Leveto’s right to counsel against the court’s interest in proceeding. *219Importantly, Leveto did not request substitute counsel; rather, he asserted his right to counsel. See Buhl v. Cooksey, 233 F.3d 783, 798 (3d Cir.2000) (making clear that a defendant seeking to dismiss counsel and proceed pro se is not moving to substitute counsel).
When prior to jury selection a defendant asks to fire counsel and proceed pro se, rather than substitute counsel, we require the trial court to safeguard the Sixth Amendment through an extensive inquiry to make certain the defendant understands the ramifications and also to “determine] if the request is merely an attempt to delay and derail proceedings, as opposed to a genuine attempt ... to conduct one’s own defense.” Id. If we are so careful when permitting a defendant to proceed pro se, must we not be equally careful — or perhaps more so — when the defendant realizes he is not capable of proceeding pro se? Given that representation by counsel is the constitutional default position, such an inquiry is no less necessary when a defendant seeks to revoke his waiver and proceed with counsel. See Brown v. Wainwright, 665 F.2d 607, 611 (5th Cir. 1982) (en banc) (“Since the right of self-representation is waived more easily than the right to counsel at the outset, before assertion, it is reasonable to conclude it is more easily waived at a later point, after assertion.”). The majority appears to concede this point, noting that “[t]he significance of representation by professional legal counsel demands that any decision that touches upon the availability of counsel must be investigated and explained on the record” — precisely what the District Court failed to do here.
United States v. Proctor, 166 F.3d 396 (1st Cir.1999), strongly supports this view. In Proctor, the defendant had engaged in highly relevant manipulative conduct, hiring and firing two lawyers while accusing them of various offenses against him, then proceeding pro se with standby counsel, and ultimately requesting counsel in the middle of an evidentiary hearing. Yet, the court of appeals held that the trial judge could not reject the defendant’s request for counsel without express findings. The court reasoned:
While Proctor’s earlier rejection of two attorneys and the timing of his most recent flip-flop over representation may have afforded some grounds for suspicion that he was seeking to manipulate the trial process to suit his own interests, these factors alone-without judicial inquiry eliciting further evidence and express findings on the issue of bad faith manipulation-were insufficiently compelling to permit a court to reject out of hand any new request for counsel. Here, the record suggests a defendant who, despite earlier confidence that he could represent himself better than his appointed attorneys, recognized the value of counsel once confronted with the inadequacy of his own legal skills in the face of actual courtroom problems.
Id. at 403. As in Proctor, the trial judge here failed to do what was necessary to safeguard the defendant’s right to counsel.
Furthermore, even where a defendant does not assert his Sixth Amendment right to counsel but merely moves for a continuance to retain substitute counsel on the eve of trial, “we require district courts to inquire as to the reason for the request.” Goldberg, 67 F.3d at 1097 (reversing although the judge had made an explicit finding that the defendant was using his right to counsel to manipulate and delay his trial). A trial court’s authority to deny such requests is carefully circumscribed. They may only be denied if shown to be made in bad faith, for purposes of delay, or to subvert judicial proceedings. United States v. Romano, 849 F.2d 812, 819 (3d *220Cir.1988); but see United States v. Rankin, 779 F.2d 956, 960 (3d Cir.1986) (observing that “a rigid insistence on expedition in the face of a justifiable request for delay can amount to a constitutional violation”). Such cases typically have lower stakes than those here, as the constitutional calculus there involves a defendant’s right to counsel of his choice, rather than the right to counsel.18 Nonetheless, where, because the court denies the request to substitute counsel, the defendant proceeds represented by counsel not of his or her choice, we will find a Sixth Amendment violation if there is no inquiry on the record. Goldberg, 67 F.3d at 1097. As we have said, “even well-founded suspicions of intentional delay and manipulative tactics can provide no substitute for the inquiries necessary to protect a defendant’s constitutional rights.” United States v. Welty, 674 F.2d 185, 189 (3d Cir.1982).19
The trial judge erred by failing to conduct any inquiry of the defendant or to develop the record as to his request. While the majority reasons through the judge’s ruling, the judge did not do so. Instead, he concluded summarily that it was too late. He did not question the sincerity of Leveto’s feelings of inadequacy or his need or desire to be represented. While trial judges should, of course, be permitted to make judgments as to the conduct of proceedings before them and should be free to exercise discretion in so doing, when the right to counsel in a complicated criminal trial is implicated, the determination by the court must be correct as a matter of law, and there must be an in-depth exploration of the desire and need for counsel — as is done when permitting a waiver at the outset — giving due consideration to the ramifications for the individual on trial. See Tuitt v. Fair, 822 F.2d 166, 174 (1st Cir.1987) (“Where the two rights [to self-representation and to counsel] are in collision, the nature of the two rights makes it reasonable to favor the right to counsel which, if denied, leaves the average defendant helpless.”). The consistent theme of our jurisprudence in this area is that a defendant should not be forced to proceed to trial without counsel. Here, I believe that occurred.
Accordingly, I dissent from the majority’s view. I would vacate Leveto’s conviction and remand for a new trial with counsel.
. Other courts of appeals have occasionally employed an abuse of discretion standard. See United States v. West, 877 F.2d 281 (4th Cir.1989) (equating substitution of counsel *213with a request to revoke waiver and using abuse of discretion standard); United States v. Merchant, 992 F.2d 1091 (10th Cir.1993) (same).
. The majority states that the standard to find a violation of the Sixth Amendment is that "the district court's good cause determination was clearly erroneous, or the district court made no inquiry into the reason for the defendant's request.” It seems to have taken this standard from cases involving requests to substitute counsel where the defendant continues with unwanted counsel, such as United States v. Goldberg where we said,
If the district court denies the request to substitute counsel and the defendant decides to proceed with unwanted counsel, we will not find a Sixth Amendment violation unless the district court's 'good cause' determination was clearly erroneous or the district court made no inquiry into the reason for the defendant's request to substitute counsel.
67 F.3d at 1097 (emphasis added). Notably, this standard only applies where the court denies the request for substitute counsel and the defendant proceeds with counsel. Here we are presented with a request to reinvoke the Sixth Amendment right to counsel where the denial forced the defendant to proceed without counsel.
. Moreover, Tolliver suggests that when a defendant seeks to reinvoke the right to counsel, the proper course of action is to let standby counsel step in wherever possible, even in the middle of trial. In that case, mid-way through the trial, Tolliver requested new counsel. 937 F.2d at 1186. The court was inclined to let stand-by counsel step in immediately until the government argued that he *214should not be forced to represent Tolliver because Tolliver had filed an ethics complaint against him; the court then agreed to continue to look for new counsel. Id. at 1186.
. At one point, the judge observed, "I don't understand why the Government insisted on the — not agreeing to the conditional plea.” App. 277. He noted that, although the government had not bargained away anything, it was requiring concessions from the defendant that he had never seen before. App. 287-88, 293-94, 295.
. When Leveto was first detained, Attorney Ross Prather was appointed as counsel, but subsequently was granted leave to withdraw because of a serious conflict of interest. At the May 24, 2004 hearing on Prather’s motion to withdraw, it was determined that the regular public defender in Erie also had a conflict. A third attorney, Patty Ambrose, who was available to meet with Leveto at that hearing, determined she had a conflict as well. At the time, Leveto indicated that his first choice was paid counsel, his second stand by counsel, and his third proceeding pro se. On June 2, 2004, the judge held another hearing on counsel and was told that, since the May 24th hearing, one other lawyer had met with Leve*216to, but, yet again, had been determined to have a conflict. Leveto requested counsel at the hearing, and the judge noted that another CJA panel lawyer should have been, but was not, present to represent him.
. In filing the recusal action, Leveto both certified that the motion was not being made to delay trial and explained that the motion had not been filed earlier because of his extremely limited access to a law library.
. The majority suggests that a statement made by defendant during the course of the trial reflects defendant’s understanding that the denial of his request prior to any trial proceedings was necessary to prevent a delay. I disagree. The statement — "I’m aware of that, Your Honor. That is, why before it started, I reasserted the right and I filed the action against you a week before the trial”— was not made on May 23, 2005 at the time the District Court denied Leveto's request for counsel. Rather, it occurred on May 31, 2005 mid-way through trial. At that time, before Leveto was to present his defense and malte an opening statement, which he had reserved, he referred to a passage in the government’s trial brief to the effect that "a defendant who has previously waived the right to counsel may be allowed to withdraw the waiver and reassert the right.” App. 339. The following ensued:
Court: You never withdrew.
Leveto: I never withdrew what?
Court: You never withdrew your choice of proceeding pro se.
Leveto: When I told you I wanted to be represented by a lawyer?
Court: The day of the trial? Or — no.
Leveto: There were other extenuating circumstances, Your Honor.
Court: Well, that’s too bad.
App. 339. The Court then said, "Under the circumstances of this case, I can’t imagine stopping now and appointing Mr. Misko or anyone to represent you and prepare to defend a case like this. You can't do it. You can’t operate that way.” App. 341. Leveto’s statement in response does not represent his agreement that, when the District Court denied his pre-trial request for counsel more than a week earlier, it was properly motivated by delay. More correctly construed, it is a simple acknowledgment that Leveto believed the request to be appropriate when he first made it, before the trial began, and accepted that a request made mid-trial would be untimely.
. See also United States v. Taylor, 933 F.2d 307, 313 n. 4 (5th Cir.1991) (discussing Leveto’s precise factual scenario here in hypothetical form and concluding that it would “[t]here can be no question that the defendant in such a case has been deprived of his right to counsel”).
. Sometimes this amounts to proceeding with counsel of his or her choice who is unprepared, prepared counsel who is unwanted, or pro se; in other situations, it involves a choice between constitutionally adequate counsel who he or she seeks to replace, and proceeding pro se.
. The majority nonetheless contends that "we do not insist upon a formal inquiry or colloquy where the rationales for the request and decision are clearly apparent on the record,” citing only United States v. Peppers, 302 F.3d 120, n. 12 (3d Cir.2002), as support. However, this footnote does not do away with our longstanding requirement of inquiry; it merely summarizes our decision in United States v. Salemo, 61 F.3d 214 (3d Cir.1995).