State v. Webber

Summary

The North Carolina Court of Appeals reviewed whether the trial court violated David Bradley Webber’s Sixth Amendment right to counsel by finding that he forfeited or waived counsel through his conduct. The court held that the trial court did not err. The opinion discusses Webber’s repeated changes in representation, conflicts with appointed and retained attorneys, waivers of appointed counsel, and his appearance without counsel before trial.

Holdings

1. Defendant did not voluntarily waive assistance of counsel because he never sought to proceed pro se and continuously sought appointed or retained counsel, notwithstanding his waivers of court-appointed counsel.
2. Defendant forfeited his right to counsel because his repeated efforts to replace or reject counsel, significant delays, refusal to accept appointed counsel, and appearance for trial without counsel constituted sufficiently egregious obstructionist conduct that undermined the purposes of the right to counsel and made representation impossible.

Questions Presented

1. Whether Defendant voluntarily waived his Sixth Amendment right to counsel.
2. Whether Defendant's conduct was sufficiently egregious and obstructive to constitute forfeiture of his right to counsel.

Disposition

other