Affirmed by published opinion. Judge RUSSELL wrote the majority opinion, in which Judges WIDENER, WILKINSON, WILKINS, NIEMEYER, HAMILTON and WILLIAMS joined. Chief Judge ERVIN wrote a dissent,, in which Judges HALL, MURNAGHAN and MICHAEL, and Sernor Judge PHILLIPS joined.
OPINION
DONALD RUSSELL, Circuit Judge:
Plaintiff Gary Fields appeals the district court’s demal of Ms habeas petition, contending that the state court that conducted his trial on sexual abuse charges unconstitutionally demed him Ms right to self-representation. A panel of this Court reversed the district court’s deMal and ordered that the writ issue. Subsequently rehearing en banc was granted. We now’ affirm the district court’s demal of Fields’ petition.
I.
During the time period relevant to this case, Fields, who is divorced, lived in a trailer home with his mother and his daughter, Deanna, who was twelve at the time. Fields and his mother occupied the two bedrooms in the home; Deanna slept,in the living room. Deanna was quite popular with her peers, and her group of young girl friends spent a great deal of time at Fields’ home, becoming so closely acquainted with Fields that they called him “dad.” Many times during the period at issue in this case they slept over at Fields’ home with Deanna.
According to the girls, a regular routine was followed during these sleep-overs. When the girls were preparing to go to sleep, Fields, gave each of them a handful of pills, telling them that the pills were vitamins. Some of the pills were vitamins but others, unidentified to the girls at the time, were sleeping pills.1 The girls would. become drowsy and, as they were falling asleep, Fields gave them backrubs. During the baekrubs, he frequently fondled their private areas. In the middle of the mght, he would often return to the living room where the [1026]*1026girls were sleeping and fondle them again. On many of these occasions, he would take one of the girls from the living room to his bedroom and rape her.
This sickening routine continued for á number of months. Three of Deanna’s friends testified that Fields had raped them' during these sleep-overs, with one indicating that she had been raped by Fields many times over a three-month period and another that it had happened on nine or ten occasions. Three other friends of Deanna stated that Fields had fondled them at these sleepovers, and one of them indicated that Fields had done this ten or more times.
Deanna testified that she as well had been sexually abused by Fields, her father. Once, purporting to explain to her about the birds and the bees, he had taken off her clothes and raped her. In a separate instance, he had fondled all of her private areas. She had difficulty recalling the details of a third occasion because she apparently had taken sleeping pills given to her by Fields.
Fields’ routine at these sleep-overs was allowed to continue for months because, as the girls testified, they were afraid to tell anyone about it. Fields’ actions only came to light when he babysat for a night for three young children of a friend, Mrs. Shackleford, whose husband was dying in the hospital. Johnny Shackleford, aged ten, refused Fields’ offer of sleeping pills and was awake to witness Fields, after spitting on his hands, fondle his ten-year-old sister Julie and his twelve-year-old sister Rose. Johnny after-wards told an adult what had occurred and, -, when Johnny’s story was corroborated by the independent statements of his two sisters and at least four other girls who had attended these sleep-overs, Fields’ revolting routine was terminated.
In May, 1988, a grand jury in Newport News, Virginia, charged Fields with six counts of aggravated sexual battery, one count of forcible sodomy, and one count of rape. The Circuit Court' for the City of Newport News appointed attorneys Oldric J. Labell, Jr.,2 and James A. Segall to represent Fields.
Prior to the trial, in June, 1988, Fields wrote to the presiding judge in his case, the Honorable Douglas M. Smith, requesting “to be appointed as co-council [sic].” He admitted: “I do this with reluctance since my knowledge of the law is limited,” and, as he acknowledged later in the letter, “I have a learning disability and related attention span defecit [sic].” Nonetheless, he wished to act as co-counsel in order to “question the witnesses [himjself” because he “firmly [believed] these kids cannot look me in the eye and lie to me. They have been treated as if they were my own kids [and] call me dad. I know them well.” He added:
I do not intend to try and intimidate the witnesses just to get them to say what they think I want them to say. In fact I will if you wish not approach them closer than three feet and I would request the courts [sic] permission if for some reason I needed to get closer.3
The panel opinion in this appeal added that, in Fields’ first letter to the state judge he “felt the complaining witnesses had lied at the preliminary hearing, and that his appointed counsel had not proven themselves capable of effectively cross-examining the witnesses. Fields explained that he needed to cross-examine the juvenile witnesses because only he had sufficient knowledge of the complex events that led to his prosecution to guarantee an effective examination.” There can be no question that in this statement Fields demonstrated that the motivation for his motion for the right to cross-examine the children was simply to secure the right to conduct such cross-examination.
On August 16, 1988, Fields wrote a second letter to Judge Smith, this time asking “for a new attorney to replace Mr. Labell [and]. Mr. Segall.” Fields explained that, for a variety of reasons, he had concluded, according to [1027]*1027the panel opinion, that his “council [sic] [could not] handle [his] defense.” We read his request to act as co-counsel as the only reason for his demand of the right to cross-examine the children. This seems clear from the summarization of this letter by the panel opinion, which said:
Fields complained that he disagreed with attorney LaBell over how to conduct his defense: “Our approaches to my defense ha[ve] been on divergent courses.” Fields accused LaBell of wanting “to conduct a defense by burying his head in law books” and of “using legalistic manipulations.” Fields explained that he wished to employ a different trial strategy: “My approach has always been to simply get the remainder of the stories from the witnesses] by questioning them myself on the stand.”
Approximately two weeks later, on August 29, 1988, after the state court had apparently not approved Fields’ request, according to the record, for new counsel,4 Fields again wrote' to Judge Smith, explaining his reason for applying for the right personally to cross-examine the children:
I heard perjury committed [sic] at the hearing and I believe the witnesses would not hesitate to lie again to a stranger. The stranger-1 am referring to would be any council [sic] asking them questions.
The state trial court held a hearing on September 7, 1988, in part to address Fields’ letters. At that hearing, the following colloquy ensued:
THE COURT: What seems to be your problem?
FIELDS: There are several problems, Your Honor. One has been no contact with my attorneys in the past. No verbal contact and—
THE COURT: Well, you indicated to me by letter that you didn’t ever want to see him. again,
FIELDS: That’s true.
THE COURT: So now you’re complaining that you haven’t seen him?
FIELDS: I had no use for him.. If they weren’t coming over, what the heck were they doing?. And when he did come over, I wasn’t asked my opinion on what had happened in the case or how I should be approached for the defense. They had already gone off their paths, and my opinions or my thoughts just weren’t relevant in that.
THE COURT: You haven’t got a legal degree, have you?
FIELDS: No, sir.
THE COURT: Don’t you think these two attorneys are better suited for what ought to be brought up in your ease and what ought not to be brought up?
FIELDS: In some respects.'
The Court then explained that he would not allow Fields to cross-examine the young girls who were witnesses against him; instead, he could “write out [his] questions and give it to [his] lawyers if [he] want[ed] to.”5 When, at the hearing, the trial judge made it plain that he would not permit Fields to cross-examine the children, Fields responded, as the panel opinion points out, “Well, then, there won’t be any justice in this courtroom.” This ended the conversation between Fields and the trial judge. Fields’ demand had not changed or “evolved.”' He was still focusing wholly on his demand to. cross-examine the children, so much so that he de-[1028]*1028dared there would “not be any justice in this courtroom” if the trial judge denied him the right to cross-examine the children. That is the unquestioned demand of Fields. If that right was given him, he said, in effect, that he would be. content.
Fields was convicted on five counts of aggravated sexual battery.6 He appealed his conviction to the Court of Appeals of Virginia, arguing, inter alia, that the trial court had refused to allow him tó proceed pro se and cross-examine personally the young girls who were witnesses against him; this refusal, he contended, violated his right to self-representation.
The State Court of Appeals .rejected this contention. Fields v. Commonwealth, No. 1697-88-1, slip op. at 3 (Va. Ct.App. Aug. 21, 1990). The Court noted that to trigger his self-representation right,1 “the defendant must knowingly waive his right to counsel by clear and unequivocal assertion of the right to self-representation.” Id. at 2-3. It found that “[t]he record ... contains no clear and unequivocal waiver of counsel. To the contrary, the record shows that [Fields] wanted, and repeatedly requested, permission only to conduct cross-examination.” Id. at 3. The Supreme Court of Virginia refused Fields’ petition for review of the court of appeals’ decision. Fields v. Commonwealth, No. 901282 (Va. Nov. 26, 1990); see Saunders v. Reynolds, 214 Va. 697, 204 S.E.2d 421, 424 (1974) (holding that Virginia Supreme Court’s refusal of petition for review operates as a ruling on the merits).
In February, 1991, Fields filed in the Eastern District of Virginia the habeas petition at issue here, making the same contention he advanced before the Court of Appeals of Virginia and the Supreme Court of Virginia. The petition was referred to. Magistrate Judge Thomas Miller, who recommended that it be denied. Fields v. Murray, No. 91-100-N, slip op. at 8 (E.D. Va. June 10, 1991). He stated: “[E]ven without the [section 2254(d) ] presumption, this Court concurs solidly with the state courts’ findings that Fields’ letters and verbal communications taken as a whole do not manifest an unequivocal demand for self-representation.” Id. at 6 (quotation omitted). The district court, after a de novo review of Fields’ contention, found “that the Magistrate Judge’s analyses of the facts and law [were] correct” and accepted the magistrate judge’s recommendation that Fields’ petition be denied. Fields v. Murray, No. 91-100-N, slip op. at 2 (E.D. Va. July 10, 1991).7
II.
We- first address the application of the Sixth and Fourteenth Amendments which the dissent argues requires that a defendant in a state criminal trial be permitted to proceed pro se, apparently without any restraints on such right, despite the presence of special circumstances in this case. Faretta v. California, 422 U.S. 806, 807, 95 S.Ct. 2525, 2527, 45 L.Ed.2d 562 (1975). Invocation of this right of self-representation, however, poses a peculiar problem: it requires that the defendant waive his right to counsel. “Of the two [rights], the right to be represented by counsel is preeminent,” United States v. Gillis, 773 F.2d 549, 559 (4th Cir.1985); see Tuitt v. Fair, 822 F.2d 166, 174 (1st Cir.) (“[T]he nature of-the two rights makes it reasonable to favor the right to counsel which, if denied, leaves the average defendant helpless.”), cert. denied, 484 U.S. 945, 108 S.Ct. 333, 98 L.Ed.2d 360 (1987); indeed, “[o]f all the rights that an accused person has, the right to be represented by counsel is by far the most pervasive, for it affects his ability to assert any other rights he may have,” Penson v. Ohio, 488 U.S. 75, 84, 109 S.Ct. 346, 352, 102 L.Ed.2d 300 (1988); see United States v. Yagow, 953 F.2d 427, 431 (8th Cir.), cert. denied, — U.S. , 113 S.Ct. 103, 121 L.Ed.2d 62 (1992). [1029]*1029So important is the right to counsel that the Supreme Court has instructed courts to “indulge in every reasonable presumption against [its] waiver.” Brewer v. Williams, 430 U.S. 387, 404, 97 S.Ct. 1232, 1242, 51 L.Ed.2d 424 (1977); see United States v. Weisz, 718 F.2d 413, 425 (D.C.Cir.1983), cert. denied, 465 U.S. 1027, 104 S.Ct. 1285, 79 L.Ed.2d 688 (1984). As a result, a defendant who desires to invoke his right to self-representation, thereby waiving his right to counsel, must do so “clearly and unequivocally.” United States v. Reddeck, 22 F.3d 1504, 1510 (10th Cir.1994); accord Stano v. Dugger, 921 F.2d 1125, 1144 (11th Cir.) (en banc), cert. denied, 502 U.S. 835, 112 S.Ct. 116, 116 L.Ed.2d 85 (1991); United States v. Lorick, 753 F.2d 1295, 1298 (4th Cir.), cert. denied, 471 U.S. 1107, 105 S.Ct. 2342, 85 L.Ed.2d 857 (1985); McNamara v. Riddle, 563 F.2d 125, 127 (4th Cir.1977).
This requirement that a defendant invoke his self-representation right clearly and unequivocally also serves an additional purpose. A trial court evaluating a defendant’s request to represent himself must “traverse ... a thin line” between improperly allowing the defendant to proceed pro se, thereby violating his right to counsel, and improperly having the defendant proceed with counsel, thereby violating his right to self-representation. Cross v. United States, 893 F.2d 1287, 1290 (11th Cir.), cert. denied, 498 U.S. 849, 111 S.Ct. 138, 112 L.Ed.2d 105 (1990); see Reese v. Nix, 942 F.2d 1276, 1280 (8th Cir.1991), cert. denied, 502 U.S. 1113, 112 S.Ct. 1220, 117 L.Ed.2d 457 (1992); Adams v. Carroll, 875 F.2d 1441, 1444 (9th Cir.1989). A skillful defendant could manipulate this dilemma to create reversible error. Cross, 893 F.2d at 1290; Adams, 875 F.2d at 1444; Tuitt, 822 F.2d at 175. The requirement that a defendant invoke his self-representation right clearly and unequivocally greatly aids the trial court in resolving this dilemma by allowing the court safely to presume that the defendant should proceed with counsel absent an unmistakable expression by the defendant that, so to proceed is- contrary to his wishes. Cross, 893 F.2d at. 1290; Adams, 875 F.2d at 1444; Tuitt, 822 F.2d at 175.
Before analyzing the state court’s finding that Fields failed to invoke his self-representation right clearly and unequivocally, we must first address the proper standard under which to review this finding. As Fields’ case reaches us on habeas, we review the state court’s findings on questions of fact under the “presumption of correctness” set forth in 28 U.S.C. § 2254(d); the state court’s findings on mixed questions of fact and law we consider de novo. Miller v. Fen-ton, 474 U.S. 104, 111-12, 106 S.Ct. 445, 450, 88 L.Ed.2d 405 (1985); Wainwright v. Witt, 469 U.S. 412, 428 & n. 8,105 S.Ct. 844, 854 & n. 8, 83 L.Ed.2d 841 (1985).8
The Supreme Court’s most complete discussion of the appropriate methodology for distinguishing these two types of questions is contained in Miller. There the. Court stated:
At least .in those instances in which Congress has not spoken and in which the issue falls somewhere between a pristine legal standard and a simple historical fact, the fact/law distinction at times has turned on a determination that, as a matter of the sound administration of justice, one judicial actor is better positioned than another to decide the issue in question.
Miller, 474 U.S. at 114, 106 S.Ct. at. 451. [1030]*1030credibility of witnesses” and, therefore, “the state trial judge is in a position to assess [it] that is far superior to that of federal judges reviewing an application for a writ of habeas corpus,” id., “there are compelling and familiar justifications for leaving the process of applying law to fact to the [state] trial court and according its determinations presumptive weight,” id.; as a result, such an issue “merits treatment as a ‘factual issue’ within the meaning of § 2254(d),” id. at 114-15, 106 S.Ct. at 452.
[1029]*1029“[F]or example,” the Court- indicated, it was more likely to classify a question as a question of law or as a mixed question of fact and law, both reviewable de novo, when “the relevant legal principle [could] be given meaning only through its application to the particular circumstances of a ease,” or when, due to the nature of the question, “federal or appellate review [would serve] as a means of compensating for perceived shortcomings of the trier of fact by way of bias or some other factor.” Id. (quotation omitted). When, the Court contrasted, “the issue involves the
[1030]*1030Applying this methodology to the case before it, the Court concluded that whether a confession was voluntary was a mixed question of fact and law’reviewable de novo. Id. at 115, 106 S.Ct. at 452. It explained that “the voluntariness of a confession has always had a uniquely legal dimension” -because “the voluntariness inquiry ... subsum[es] ... a complex of values;”, this “militates against treating the question as one of simple historical fact,” id. at, 116, 106 S.Ct. at 452-53 (quotation omitted). In addition, the Court indicated, as “assessments of credibility and demeanor are not crucial” in determining whether a confession was voluntary, id. at 116-17, 106 S.Ct. at 453, “the state-court judge [was] not in an appreciably better position than the federal habeas court to make that determination,” Id. at 117, 106 S.Ct. at 453. Finally, the Court noted that “the critical events surrounding the taking of a confession” do not “take place in open court on á full record,” but “almost invariably occur in a secret and inherently more coercive environment,” id.; these circumstances, “together with the inevitable and understandable reluctance to exclude an otherwise reliable admission of guilt,” id. at 117, 106 S.Ct. at 453, “elevate[d] the risk that .erroneous resolution of the voluntariness question might inadvertently frustrate .the protection of the federal right,” id.~
Miller, distilled, sets forth that, at least in the absence of a statement by Congress, a question should be classified as one of fact or of fact and law mixed based on which “judicial actor is better positioned ... to decide [it],” id. at 114, 106 S.Ct. at 451; questions which the federal habeas court is better positioned to decide should be classified as mixed questions of fact and law and reviewed de novo, while questions which “the state trial judge is in a [better] position to assess” should be treated as questions of fact and reviewed under section 2254(d)’s presumption of correctness, id. Three factors should be examined in determining whether the federal habeas court or the state court is better positioned to decide the question: first, whether the legal standard to be applied is complex or simple and straightforward, id. at 114, 115-16, 106 S.Ct. at 451, 452-53; second, whether observing the state trial court proceedings is important in resolving the question, id. at 114, 116-17, 106 S.Ct. at 451, 453; third, whether allowing the state court to decide the question poses an “elevate[d] ... risk,” id. at 117, 106 S.Ct. at 453, because of “bias or some other factor,” id. at 114, 106 S.Ct. at 451, that the constitutional right at issue will not be properly protected, id. at 117, 106 S.Ct. at 453.
The methodology set forth in Miller for distinguishing questions of fact from mixed questions of fact and law sheds light on the Court’s other decisions in this area, an area in which the Court has acknowledged that it “has not charted an entirely clear course.” Id. at 113, 106 S.Ct. at 451. In Wainwright v. Witt, 469 U.S. 412, 429, 105 S.Ct. 844, 855, 83 L.Ed.2d 841 (1985), and Patton v. Yount, 467 U.S. 1025, 1036, 104 S.Ct. 2885, 2891, 81 L.Ed.2d 847 (1984), for example, the Court held that the question of whether jurors were biased, in violation of the defendant’s Sixth Amendment right to an impartial jury, was one of fact. The Court stated: “The trial judge is of course applying some kind of legal standard to what he sees and hears, but his predominant function in determining juror bias involves credibility findings whose basis cannot be easily discerned from an appellate record. These are the ‘factual issues’ that are subject to § 2254(d).” Wainwright, 469 U.S. at 429, 105 S.Ct. at 855. In addition, the Court later noted that the state court’s “determination of juror bias .... take[s] place in open court on a full record “ and, for that reason, serves as an example of a determination to which the federal habeas court can defer without an elevated risk to the defendant’s constitutional rights. Miller, 474 U.S. at 117, 106 S.Ct. at 453.
[1031]*1031In a similar vein lie Demosthenes v. Baal, 495 U.S. 731, 735, 110 S.Ct. 2223, 2225, 109 L.Ed.2d 762 (1990), and Maggio v. Fulford, 462 U.S. 111, 117, 103 S.Ct. 2261, 2264, 76 L.Ed.2d 794 (1983), where the Court held that whether a defendant was competent, respectively, to waive post-conviction relief or to stand trial were questions of fact. The state court’s position in having observed the defendant during the trial court proceedings gives it an advantage oyer the federal habeas court in determining whether the defendant is competent. Miller, 474 U.S. at 116-17, 106 S.Ct. at 453. Further, as “the adjudication of competency ... take[s] place in open court on a full record,” there is not an elevated risk that deference to the state court’s competency determination will leave the defendant’s constitutional rights unprotected. Id. at 117, 106 S.Ct. at 453.
With Miller's, methodology in mind, we turn to classifying the question at issue here, whether Fields effectively invoked his right to self-representation, as one of fact or one of fact and law mixed. On Miller’s first factor, the legal standard to be applied in resolving the question is whether the defendant expressed his desire to proceed pro se “clearly and unequivocally.” Applying this standard is simple and straightforward, for clarity and unequivocality are not sophisticated legal concepts but common, ordinary terms easily understood by a layman; by contrast, the standard is not comprised of “a complex of values,” as is the standard for determining whether a confession is voluntary, id. at 116, 106 S.Ct. at 453.
Observation of the state trial court proceedings is important in resolving whether the defendant clearly and unequivocally expressed his desire to proceed pro se, Miller ’s second factor. The clarity and unequivocality of a defendant’s expression is determined not only by the words he speaks, but by his way of speaking them and his manner and demeanor When he is speaking;' undeniably, the same words can express different degrees of certainty depending on how they are spoken. A transcript of the state trial court proceedings can reveal neither the way a defendant spoke when he indicated his desire to represent himself nor the manner and demeanor he assumed at the time of this indication.
As to Miller’s third factor, allowing a state court to determine whether a defendant clearly and unequivocally expressed his desire to proceed pro se does not pose an “elevate[d] ... risk” that the defendant’s constitutional right at issue, his right to self-representation, will not be properly protected. The primary consideration in evaluating whether there is elevated risk to the constitutional' right at issue is the location where the critical events to be examined by the court occurred, id. at 117, 106 S.Ct. at 453; thus, Miller found an elevated risk when a state court determined the voluntariness of a confession because “the critical events surrounding the taking of a confession almost invariably occur in a secret ... coercive environment,” id., while distinguishing cases where the critical events to be examined by the court “take place in open court on a fall record,” id. The critical event examined by the state court in determining whether a defendant clearly and unequivocally expressed his desire to proceed pro se is the defendant’s expression of that desire, and that expression' should “take place in open court on a full record,” id.
Another consideration in deciding whether allowing a state court to determine the question at issue poses an elevated risk to the defendant’s constitutional right is whether the state court is likely to be biased'against the defendant in its determination. A state court is unlikely to be affected by bias in determining whether a defendant clearly and unequivocally invoked his right to self-representation. This is not a determination where resolution in the defendant’s favor will increase the probability of an acquittal, as in a state court determination of whether a confession is voluntary, see id. at 117, 106 S.Ct. at 453; rather, a determination in the defendant’s, favor here means that he represents himself which; if anything, is more likely to produce a conviction, see McKaskle v. Wiggins, 465 U.S. 168, 177 n. 8, 104 S.Ct. 944, 950 n. 8, 79 L.Ed.2d 122 (1984) (“[T]he right of self-representation is a right that when exercised usually increases the likelihood of a trial outcome unfavorable to the defen-[1032]*1032dant_”)• -Of course, some state courts may prefer, for the sake of efficient administration of the trial, that the defendant proceed with counsel, but this possible preference alone is insufficient to justify a finding that state court determination of whether the defendant effectively invoked his self-representation right poses an elevated risk to this right.
In sum, then, with regard to the question of whether a defendant effectively invoked his right to self-representation, we find that the legal standard to be applied is simple and straightforward, that observing the state trial court proceedings is important in resolving the question, and that allowing the state court to determine the question does not pose an elevated risk to the defendant’s self-representation right. As a result, under Miller, we conclude that the question is one of fact and, therefore, that the state court’s finding on the question is reviewed under section 2254(d)’s “presumption of correctness.”
Our conclusion is supported by the decisions of the only other courts of appeals to address the issue. In Cain v. Peters, 972 F.2d 748, 749 (7th Cir.1992), cert. denied, — U.S. -, 113 S.Ct. 1310, 122 L.Ed.2d 698 (1993), and Hamilton v. Groose, 28 F.3d 859, 862 (8th Cir.1994), the Seventh and Eighth Circuits both held that whether a defendant “clearly and unequivocally” invoked his right to self-representation was a question of fact and, therefore, the state court’s finding on it was reviewed by the federal habeas court under section 2254(d).9
Section 2254(d) commands that a state court’s determination on a question of fact “shall be presumed to be correct,” 28 U.S.C. § 2254(d), unless one of eight “enumerated reasons for avoiding the presumption is present,” Wainwright, 469 U.S. at 431, 105 S.Ct. at 856.10 Reasons one through seven are plainly inapplicable, see 28 U.S.C. § 2254(d)(1)-(7);11 thus, we can only overturn [1033]*1033the state court’s finding that Fields failed to invoke his right to self-representation clearly and unequivocally if it is “not fairly supported by the record,” 28 U.S.C. § 2254(d)(8). Such a review compels us to accord the state court’s finding “a high measure of deference.” Rushen v. Spain, 464 U.S. 114, 120, 104 S.Ct. 453, 456, 78 L.Ed.2d 267 (1983); Sumner v. Mata, 455 U.S. 591, 598, 102 S.Ct. 1303, 1307, 71 L.Ed.2d 480 (1982). “This deference requires that a federal habeas court more than simply disagree with the state court before rejecting its factual determinations. Instead, it must conclude that the state court’s findings lacked even ‘fair support’ in the record.” Marshall v. Lonberger, 459 U.S. 422, 432, 103 S.Ct. 843, 850, 74 L.Ed.2d 646 (1983); see Wainwright, 469 U.S. at 434, 105 S.Ct. at 857.
Applying this “high measure of deference,” Rushen, 464 U.S. at 120, 104 S.Ct. at 456, we cannot conclude that the state court’s finding that Fields failed to invoke his right to self-representation clearly and unequivocally “lacked even ‘fair support’ in the record,” Lonberger, 459 U.S. at 432, 103 S.Ct. at 850. Over the course of his three letters and his subsequent hearing before the state trial court, Fields only mentioned the possibility of proceeding pro se at one point, in his third letter to Judge Smith. There, in the midst of complaining about the performance of his counsel and expressing his dismay that the court had not approved his request for new counsel, Fields stated: “I have no choice left but .to dismiss Mr. Labell and Mr. Segall as my council [sic] and act as my own council [sic] at the trial.” Shortly after the statement he added: “In July of this year the Supreme Court affirmed my right to face my accusers_” This suggests, that he may have been thinking about simply cross-examining personally the witnesses against him, rather than proceeding pro se. Moreover, even if he did intend to express a desire to proceed pro se, he indicated later in the same letter that he “regretfted] taking this action.” He had previously informed the trial court that he was “reluctan[t]” even to act as co-counsel “since [his] knowledge of the law [was] limited,” and acknowledged to the trial court that he had “a learning disability and related attention span defeeit [sic].”
Most significantly, when the trial court held a hearing to address Fields’ letters, Fields never once expressed any desire to represent himself. 'When the .Trial court asked, “[w]hat seems to be your problem,” Fields responded that he had “no contact with [his] attorneys.” When the trial court inquired, “[d]on’t you think these two attorneys are better suited for what ought to be brought up in your case and what ought not to be brought up,” Fields agreed “[i]n some respects.” When the trial court queried, “why do you think I should relieve Mr. Labell and Mr. Segall from your ease when your case is set October 3rd and 4th and you say you want a speedy trial? Anybody that gets in it now is certainly going to want a continuance in all probability,” Fields replied that “I am not aware that they’ve really done that much since April since the hearing.” Missing from all of these responses, and indeed from the entire hearing, is any expression whatsoever from Fields that he desired to proceed pro se.
The record taken as a whole, therefore, discloses only a single statement in one letter from Fields that perhaps indicated a desire to proceed pro se, although it is not entirely clear that Fields intended it as such. In the same letter, Fields expressed “regret [about] taking this action,” and had earlier informed the trial court of his “reluctance” even to act as co-counsel. Further, at a subsequent [1034]*1034hearing to address his letters, Fields never once indicated that he wished to represent himself. We cannot find, on these facts, that the state court’s determination that Fields failed to invoke his right to.self-representation clearly and unequivocally “lacked even ‘fair support’ in the record,”Lonberger, 459 U.S. at 432, 103 S.Ct. at 850.
The findings.of the other courts who have examined this same record strongly bolster our conclusion. Three different courts have conducted four independent, de novo reviews of Fields’ contention,12 and all have determined that Fields failed to invoke his right to self-representation clearly and unequivocally. It would be- difficult indeed to hold not merely .that we “simply disagree,” id., with the four independent determinations ,of these three courts, but that all of their determinations “lacked even ‘fair support’ in the record.” Id.
Because we cannot conclude that it lacked even fair support in the record, the state court’s finding that Fields failed to invoke his right to self-representation clearly and unequivocally must be upheld. We hold, therefore, that the district court did not err in determining that Fields’ right to self-representation was not violated and' denying Fields’ habeas petition.
III.
Even if Fields did invoke his self-representation right clearly and unequivocally, the state trial court committed no error. Fields concedes that he desired to proceed pro se for only one purpose: to cross-examine personally the young girls, including his daughter, who were witnesses against him. Br. for Appellant at 14 (“Fields invoked his right to self-representation as part of a calculated defense strategy: He demanded to represent himself so that he could personally cross-examine the witnesses.,. ”). The trial court refused to allow such personal cross-examination, offering instead that Fields could write out the questions that he wished to ask the girls and have them read by a lawyer. Because the trial court was not required to allow such personal cross-examination, Fields was denied nothing to which he was entitled;
Our analysis of whether the state trial court properly prevented Fields from cross-examining the -young girls who were witnesses against him begins with the Supreme Court’s opinion in Maryland v. Craig, 497 U.S. 836, 110 S.Ct. 3157, 111 L.Ed.2d 666 (1990). The Court in Craig addressed the constitutionality of a state statute that allowed child victims of sexual abuse to testify against their alleged abuser out of his presence and outside of the courtroom by one-way closed circuit television. It held that a defendant’s Confrontation Clause right can bé restricted by preventing him from confronting face-to-face" the -witnesses against him,' which is one “element” of this right, if, first, the purpose of the Confrontation Clause, ensuring “the reliability of the testimony,” is “otherwise assured” and, second, the “denial of such [face-to-face] confrontation is necessary to further an important public policy.” Id. at 850, 110 S.Ct. at 3166.
The Court found, on the first prong, that the statute “adequately ensure[d]” the reliability of the child witnesses’ testimony because, while it eliminated the defendant’s face-to-face confrontation with the witnesses, it preserved the “other elements of confrontation — oath, cross-examination, and observation of the witness’ demeanor [by the jury].” Id. at 851, 110 S.Ct. at 3166. On the second prong, the Court determined that “a State’s interest in the physical and psychological well-being of child abuse victims” was “sufficiently important to outweigh ... a defendant’s right to face his or her accusers in court” if denial of this face-to-face confrontation was necessary to protect the children from “emotional trauma.” Id. at 853-55,110 S.Ct. at 3167-68. The Court instructed that to find adequately that denial of face-to-face confrontation was necessary to protect the children from emotional trauma, the state court must “hear evidence,” id. at 855, 110 S.Gt. at 3169, and conclude that each child would be traumatized “by the presence of the [1035]*1035defendant,” id. at 856, 110 S.Ct. at 3169. Because the state statute required such a finding before denying face-to-face confrontation, the Court upheld its constitutionality. Id. at 857, 110 S.Ct. at 3169-70.
If a defendant’s Confrontation Clause right can be limited in the manner provided in Craig, we have little doubt that a defendant’s self-representation right can be similarly limited. While the Confrontation Clause right is guaranteed explicitly in the Sixth Amendment, U.S. Const, amend. YI (“In all criminal prosecutions, the accused shall enjoy the right ... to be confronted with the witnesses against him.”), the self-representation right is only implicit in that Amendment, Faretta v. California, 422 U.S. 806, 819, 95 S.Ct. 2525, 2533, 45 L.Ed.2d 562 (1975). The self-representation right was only firmly established in 1975 in Faretta, and then only over the dissent of three justices, id. at 836, 95 S.Ct. at 2542 (Burger, C.J., dissenting, joined by Blackmun and Rehnquist, JJ.). Moreover, it is universally recognized that the self-representation right is not absolute. See, e.g., McKaskle v. Wiggins, 465 U.S. 168, 176-77, 104 S.Ct. 944, 950, 79 L.Ed.2d 122 (1984); Bassette v. Thompson, 915 F.2d 932, 941 (4th Cir.1990), cert. denied, 499 U.S. 982, 111 S.Ct. 1639, 113 L.Ed.2d 734 (1991).
We must, therefore, apply Craig’s analysis to determine whether the state trial court was constitutionally required to allow Fields to cross-examine, personally the young girls who were witnesses against him., Under this analysis, Fields’' self-representation right could have been properly restricted by preventing him from cross-examining personally some of the witnesses against him, which is one “element” of the self-representation right, if, first, the purposes of. the self-representation right would have been otherwise assured and, second, the denial of such personal cross-examination was necessary to further an important public policy.
On the first prong, the purposes of the self-representation right are to allow the defendant “to affirm [his] dignity and autonomy” and to present what he believes is his “best possible defense.” McKaskle, 465 U.S. at 176-78, 104 S.Ct. at 950-51. Just as the Court in Craig determined that the purpose of the defendant’s Confrontation Clause right, ensuring the reliability of the testimony, was “otherwise assured” when one element of the right,'face-to-face confrontation with the witnesses, was denied but the other elements of the right, oath, cross-examination, and observation of the witness’ demeanor by the jury, were preserved, Craig, 497 U.S. at 850-51, 110 S.Ct. at 3166, we find that the purposes of the self-representation right would have been otherwise assured in the case at bar had Fields been tried pro se and prevented from cross-examining the girls who were witnesses against him. .
The elements of a defendant’s self-representation right include “controlling] the organization and content of his own defense, ... mak[ing] motions, ... argufing] points of law, ... participating] in the voir dire,. ... questioning] witnesses, and ... addressing] the court and the jury at appropriate points in the trial.” McKaskle, 465 U.S. at 174, 104 S.Ct. at 949. As in Craig, one of these numerous elements, the right, to question, or cross-examine, certain witnesses personally, was denied to Fields while the others would have been preserved. Denying personal cross-examination may have inhibited Fields’ dignity and autonomy to some degree by affecting “the jury’s perception that [he was] representing himself,” id. at 178, 104 S.Ct. at 951, but, as he would have conducted every other portion of the trial, his dignity and autonomy would have been “otherwise assured.” Craig, 497 U.S. at 850, 110 S.Ct. at 3166; see McKaskle, 465 U.S. at 182, 104 S.Ct. at 953 (allowing-trial court to require standby counsel for pro se defendant even though it “may erode the dignitary values the right to self-representation is intended to promote”). Similarly, while Fields’ ability to present his chosen defense may have been reduced slightly by not being allowed personally to cross-examine the girls, it would have been otherwise assured because he could have personally presented his defense in every other portion of the trial and could even have controlled the cross-examination by specifying the questions to be asked. As a result, we are convinced that-the purposes of the self-representation right were better “otherwise assured” here, despite the denial [1036]*1036of personal cross-examination, than was the purpose of the Confrontation Clause right in Craig when the defendant was denied face-to-face confrontation with the witnesses.
As to Craig’s second prong, the State had an extremely important interest in preventing Fields from personally cross-examining the young girls here. The Court in Craig determined that “a State’s interest in the physical and psychological well-being of child abuse victims” was “sufficiently important to outweigh ... a defendant’s right to face his or her accusers in court” if denial of this face-to-face confrontation was necessary to protect the children from “emotional trauma.” Craig, 497 U.S. at 853-55, 110 S.Ct. at 3167-69. The State’s interest here in protecting child sexual abuse victims from the emotional trauma of being cross-examined by their alleged abuser is at least as great as, and likely greater than, the State’s interest in Craig of protecting children from the emotional harm of merely having to testify in their alleged abuser’s presence. We have little trouble determining, therefore, that the State’s interest here was sufficiently important to outweigh Fields’ right to cross-examine personally witnesses against him if denial of this cross-examination was necessary to protect the young girls from emotional trauma.
This determination accords with those of other courts who have considered the issue. See State v. Taylor, 562 A.2d 445, 454 (R.I. 1989) (holding that a defendant charged with abusing a child could be denied the right personally to cross-examine the victims when such cross-examination would harm victims); State v. Estabrook, 68 Wash.App. 309, 842 P.2d 1001, 1006 (same), review denied, 121 Wash.2d 1024, 854 P.2d 1084 (1993); cf. Commonwealth v. Conefrey, 410 Mass. 1, 570 N.E.2d 1384, 1390-91 (1991) (refusing to reach issue because trial court failed to make adequate finding that personal cross-examination would harm child victims).
The trial court here found that preventing Fields'from cross-examining the girls who were witnesses against him was necessary to protect the girls from emotional trauma. In making this finding, it had before it the indictment, which charged Fields with raping, sodomizing, and sexually battering these girls, aged eleven through thirteen, one of whom was his daughter. It also had before it Fields’ first letter, which stated that all of these girls “eall[ed] him dad,” and that he had treated them “as if they were [his] own kids.” This letter admitted that one of these girls had “burst into tears” at a preliminary hearing “because she was embarrassed” and that the same girl “had wet the bed repeatedly.” Further, Fields declared in this letter that in cross-examining the girls he would “not approach them closer than three feet and ... would request the courts [sic] permission if for some reason he needed to get closer;” despite Fields’ protestations to the contrary, it can be inferred from this statement that Fields’ intention in the cross-examination was to intimidate the girls, especially given their close relationship to him. We think it reasonable for the trial court to have concluded on the basis of the facts before it that these eleven through thirteen-year-old girls who had experienced repeated sexual abuse would be emotionally harmed if they were personally cross-examined in open court- by Fields, their alleged abuser. We therefore find adequate the trial court’s determination that denial of this personal cross-examination was necessary to prevent emotional trauma to the girls.
We recognize that it may be argued Craig requires a more elaborate finding by the trial court that denial of face-to-face confrontation was necessary to prevent emotional harm to the child witnesses; the Court in Craig indicated that the trial court should “hear evidence,” Craig, 497 U.S. at 855, 110 S.Ct. at 3169, and conclude whether each child would be traumatized “by the presence of the defendant” in the courtroom during her testimony, id. at 856, 110 S.Ct. at 3169. The case at bar is different however. It is far less difficult to conclude that a child sexual abuse victim will be emotionally harmed by being personally cross-examined by her alleged abuser than by being required merely to testify in his presence. Further, the right denied here, that of cross-examining witnesses personally, lacks the fundamental importance of the right denied in Craig, that of confronting adverse witnesses [1037]*1037face-to-faee. As a result, we do not believe it was essential in this ease that psychological evidence of the probable emotional harm to each of the girls be presented in order for the trial court to find that denying Fields personal cross-examination was necessary to protect them.13
In sum, the purposes of Fields’ self-representation right, to allow Fields to affirm his dignity and autonomy and to present what he believes is his best possible defense, would have been “otherwise assured,” Craig, 497 U.S. at 850, 110 S.Ct. at 3166, even though he was prevented from cross-examining personally the girls who were witnesses against him..
Further, the trial court adequately found that preventing this cross-examination was necessary to further the State’s important interest in protecting child sexual abuse victims from further trauma. Under Craig, therefore, the trial court was not required to allow Fields to cross-examine personally the girls who were witnesses against him. Because Fields concedes that, this personal cross-examination was his sole purpose in representing himself, the trial court committed no error even if Fields invoked his self-representation right clearly and unequivocal-iy.
rv.
For the reasons stated, we affirm the district court’s denial of Fields’ habeas petition.
AFFIRMED.