The Court of Appeals recently clarified that when criminal defendants wish to waive their right to counsel and represent themselves, the trial court does not need to specifically apprise the defendants of the maximum amount of time to which they could potentially be sentenced. In People v. Blue, Judge Caitlin J. Halligan, joined by Chief Judge Wilson and Judges Garcia, Singas, Cannataro and Troutman, rejected the bright-line rule urged by the defendant and by Judge Jenny Rivera in her dissenting opinion that would have prohibited courts from finding that a defendant had made a knowing and intelligent waiver of his right to counsel unless he had been specifically informed of the length of any potential maximum sentence.