Read the following excerpt from a US court opinion:
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and has not competently and intelligently waived his constitutional right, the Sixth Amendment stands as a jurisdictional bar to a valid conviction and sentence depriving him of his life or his liberty.” Id. at 494, 114 S.Ct. at 1737 (emphasis added) (quoting Johnson v. Zerbst, 304 U.S. 458, 468, 58 S.Ct. 1019, 1024, 82 L.Ed. 1461 (1938)). Thus, Custis contemplated that the procedural bar applied in cases where defendants waived their right to counsel. [¶ 7.] The federal circuits analyzing Custis confirm that conclusion. See United States v. Rubio, 629 F.3d 490, 493-94 (5th Cir.2010) (denying collateral attack on prior convictions because the defendant failed to meet his burden of showing an invalid waiver of counsel); United States v. Reyes-Solano, 543 F.3d 474, 478 (8th Cir. 2008) ; United States v. Krejcarek, 453 F.3d 1290,
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What is the most suitable continuation to the opinion? Your options are:
A. holding right to testify was federal constitutional right
B. holding that a defendant cannot collaterally challenge a prior conviction used to calculate criminal history points
C. holding that the prior conviction was valid for calculation of the defendants criminal history because his waiver of the right to counsel was valid
D. holding mississippi convictions counted as criminal history points because the defendant did not testify that he was unaware of his right to counsel or that his waiver was invalid
E. holding that an express waiver of the right to appeal the sentence was invalid because the trial court had failed properly to advise the defendant and that the defendant therefore did not waive his right to appeal the legality of his sentence
Reply with [A, B, C, D, E] only.