Editing Gideon v. Wainwright (section)

===Waiving the right to counsel===
''Doughty v. Maxwell'' demonstrates the differences between how states and the federal government address standards for waiver of the right to counsel. In this case, the Supreme Court granted certiorari and reversed the decision of the Ohio court in ''Doughty'', which held that regardless of ''Gideon'', the defendant waived their right to appointed counsel by entering a plea of guilty. The underlying alleged crime and trial in ''Doughty'' took place in [[Ohio]], which had its own way of interpreting the right to counsel, as do many states. [[Pennsylvania]] and [[West Virginia]] also deemed that the right to counsel was waived when a plea of guilty was entered. Depending upon one's viewpoint, rules such as these could be seen as an attempt by a state to establish reasonable rules in criminal cases or as an attempt to save money even at the expense of denying a defendant due process. This varies a great deal from federal law, which generally has stricter guidelines for waiving the right to counsel. An analogous area of criminal law is the circumstances under which a criminal defendant can waive the right to trial. Under federal law, the defendant can only waive their right to trial if it is clear that the defendant understands the "charges, the consequences of the various pleas, and the availability of counsel".<ref>{{cite journal |year=1964 |title=Waiver of the Right to Counsel in State Court Cases: The Effect of ''Gideon v. Wainwright'' |journal=University of Chicago Law Review |volume=31 |issue=3 |pages=591–602 |doi=10.2307/1598554|jstor= 1598554 |url=https://chicagounbound.uchicago.edu/uclrev/vol31/iss3/8 }}</ref> State laws on the subject are often less strict, making it easier for prosecutors to obtain a defendant's waiver of the right to trial.