The trial judge must unconditionally and unequivocably demonstrate in the record that the defendant intelligently, voluntarily, and understandingly waived the constitutional right to counsel, whether or not the defendant is indigent. Keller v. State, 75 Wis. 2d 502, 249 N.W.2d 773 (1977). When a state agency seeks to enforce its orders through the coercion of imprisonment for contempt, the full constitutional right to counsel arises. Ferris v. State ex rel. Maass, 75 Wis. 2d 542, 249 N.W.2d 789 (1977). One charged with a crime carrying a penalty of incarceration has the full constitutional right to counsel, regardless of whether incarceration is ordered. State ex rel. Winnie v. Harris, 75 Wis. 2d 547, 249 N.W.2d 791 (1977). The mere fact that one attorney represents two defendants charged in the same crime is not sufficient evidence of inadequate representation. The defendant has the burden of showing by clear and convincing evidence that an actual and operative conflict existed. Harrison v. State, 78 Wis. 2d 189, 254 N.W.2d 220 (1977). A defendant has no right to be actively represented in the courtroom both by self and by counsel. Moore v. State, 83 Wis. 2d 285, 265 N.W.2d 540 (1978). Discussing the test to determine if the denial of a continuance acted to deny a defendant either due process or effective assistance of counsel. State v. Wollman, 86 Wis. 2d 459, 273 N.W.2d 225 (1979). Discussing withdrawal of a guilty plea on the grounds of ineffective representation by trial counsel. State v. Rock, 92 Wis. 2d 554, 285 N.W.2d 739 (1979). A defendant’s request on the morning of trial to represent himself was properly denied as untimely. Hamiel v. State, 92 Wis. 2d 656, 285 N.W.2d 639 (1979). A prerequisite to a claim on appeal of ineffective trial representation is preservation of trial counsel’s testimony at a postconviction hearing in which the representation is challenged. State v. Machner, 92 Wis. 2d 797, 285 N.W.2d 905 (Ct. App. 1979). The trial court did not err in refusing the defendant’s request on the second day of trial to withdraw a waiver of the right to counsel. Discussing self-representation. Pickens v. State, 96 Wis. 2d 549, 292 N.W.2d 601 (1980). The right to counsel did not preclude incarceration for a second operating while intoxicated conviction when the defendant was not represented by counsel in proceedings leading to the first conviction, since the first offense was a civil forfeiture case. State v. Novak, 107 Wis. 2d 31, 318 N.W.2d 364 (1982). Counsel was ineffective for failing to raise the heat-of-passion defense in a murder case when the wife who had been maltreated during a 23-year marriage intentionally killed her husband while he lay sleeping. State v. Felton, 110 Wis. 2d 485, 329 N.W.2d 161 (1983). A defendant’s uncorroborated allegations will not support a claim of ineffective representation when counsel is unavailable to rebut the claim of ineffectiveness. State v. Lukasik, 115 Wis. 2d 134, 340 N.W.2d 62 (Ct. App. 1983). Effective assistance of counsel was denied when the defense attorney did not properly inform the client of the personal right to accept a plea offer. State v. Ludwig, 124 Wis. 2d 600, 369 N.W.2d 722 (1985). When a trial court fails to make adequate inquiry into a defendant’s last-minute request to replace the defendant’s attorney, the right to counsel is adequately protected by a retrospective hearing at which the defendant may present the defendant’s own testimony. State v. Lomax, 146 Wis. 2d 356, 432 N.W.2d 89 (1988). Defense counsel’s absence at the return of the jury verdict without the defendant’s consent and the failure to poll the jury were grounds for automatic reversal. State v. Behnke, 155 Wis. 2d 796, 456 N.W.2d 610 (1990). When a defendant accepts counsel, the decision to assert or waive a constitutional right is delegated to the attorney. The failure of the defendant to object to the attorney’s waiver is waiver. State v. Wilkens, 159 Wis. 2d 618, 465 N.W.2d 206 (Ct. App. 1990). There is a two-prong test for ineffective counsel: 1) trial counsel was ineffective; and 2) the defense was prejudiced so that absent error the result would have been different. State v. Wilkens, 159 Wis. 2d 618, 465 N.W.2d 206 (Ct. App. 1990). A court may disqualify a defendant’s chosen counsel over the defendant’s objection and waiver of the right to conflict-free representation when actual or a serious potential for a conflict of interest exists. State v. Miller, 160 Wis. 2d 646, 467 N.W.2d 118 (1991). A determination of indigency by the public defender under s. 977.07 is not the end of the court ’s inquiry into the need to appoint counsel. State v. Dean, 163 Wis. 2d 503, 471 N.W.2d 310 (Ct. App. 1991). The question of ineffective counsel is whether there is a reasonable probability that a jury viewing the evidence untainted by counsel’s errors would have had a reasonable doubt respecting guilt. State v. Glass, 170 Wis. 2d 146, 488 N.W.2d 432 (Ct. App. 1992). A defense attorney’s ex parte petition to withdraw was improperly granted. A minimal due process hearing was required. State v. Batista, 171 Wis. 2d 690, 492 N.W.2d 354 (Ct. App. 1992). Absent a clear waiver of counsel and a clear demonstration of a defendant’s ability to proceed pro se, courts are advised to mandate full representation by counsel. State v. Haste, 175 Wis. 2d 1, 500 N.W.2d 678 (Ct. App. 1993). The proper test of attorney performance is reasonableness under prevailing professional norms. Counsel is not required to have a total and complete knowledge of all criminal law, no matter how obscure. State v. Hubert, 181 Wis. 2d 333, 510 N.W.2d 799 (Ct. App. 1993). Appellate counsel’s closing of a file because of no merit without the defendant knowing of the right to disagree and compel a no merit report under s. 809.32 is ineffective assistance of counsel. A defendant must be informed of the right to appeal and to a no merit report, but need not be informed orally. State ex rel. Flores v. State, 183 Wis. 2d 587, 516 N.W.2d 362 (1994).