the frendak rationale, that a judge may not impose a sanity defense over the objections of the defendant, has been used mostly in federal cases. some states have endorsed less elaborate procedures. for example, if a judge rules that the waiver of the insanity defense is not voluntary and informed, yet nonetheless the defense is imposed over the defendant's objections, then a separate counsel must be appointed to argue issues pertaining to insanity issues, while the defendant's counsel presents the arguments the defendant desires.