Wild Speculation:

This phrase from Justice Scalia's dissent in Indiana v. Edwards is a foreshadowing of a phrase in one of the pro-individual-rights opinions in D.C. v. Heller: "As I have explained, I would not adopt an approach to the right of self-representation that we have squarely rejected for other rights -- allowing courts to disregard the right when doing so serves the purposes for which the right was intended." We'll see in a few days whether I'm right.