Bustamante-Cuadros v. United States

How later courts describe this case

• “[F]orcing a criminal defendant to go to trial pro se” without conducting an appropriate inquiry into his financial ability to afford counsel “constitutes a denial of that defendant’s sixth amendment right to counsel.”
• "Though the magistrate used the term ‘indigen-cy,’ we believe that this was merely a ‘shorthand expression’ of financial inability to afford counsel.”
• test is defendant’s financial inability to obtain the services of retained counsel