Jones v. State

The appellate courts of this State are regularly asked to consider whether in a given case there has been strict compliance with Maryland Rule 4-215, which governs the procedure by which a criminal defendant waives the constitutional right to representation by counsel. Typical appellate challenges ask whether the circuit court complied with the requirements of the rule when accepting a defendant’s express waiver of the right to counsel or determining that a defendant has waived the right to counsel by inaction. Less typical is the challenge that asks whether the court complied with the rule’s…