"Moving toward requiring magic words"?

From Law.com:

11th Circuit Considers What to Do When Defendant Wants to Fire Public Defender - In rare en banc review, court will re-examine what constitutes waiver of right to counsel

Sometimes a criminal defendant wants to fire his court-appointed lawyer, even a lawyer that everyone else in the courtroom thinks is a good one.

"Some people just are irrational about their case, and they make bad decisions," said DeKalb County, Ga., public defender Lawrence L. Schneider. "They carry their bad decisions all the way into the penitentiary."

But in two recent cases, the 11th U.S. Circuit Court of Appeals has reversed convictions of defendants who could not afford their own lawyer but fired the one provided by the state -- meaning they represented themselves at trial despite their indications they didn't want to do so...