Whether in a particular case someone did or did not voluntarily waive his right to counsel is a question of fact, not a question of law.
If a person was really coerced into waiving his right to counsel, his constitutional rights were violated. That is true WHETHER OR NOT the law as a constitutional matter is as set forth in Michigan vs Jackson.
Stick to football.
If you would read the briefs, you would see that the facts demonstrate that his waiver was not voluntary.