Bultron v. State

RIDGELY, Justice.

Defendant Luis Buitrón appeals his convictions by a Superior Court jury of second-degree burglary and misdemeanor theft. Buitrón argues that the Superior Court erred by permitting his counsel to withdraw, by failing to appoint new counsel, and by requiring Buitrón to proceed pro se. The Superior Court determined that Buitrón waived or forfeited his right to counsel by his serious misconduct involving ongoing abuse of his attorney that was just short of violence. Whether a defendant waives or forfeits his right to counsel through ongoing abusive conduct is an issue of first…