Morgan v. State

In the short time since we last spoke on the matter of jury waivers, it has become clear that greater specificity is needed regarding how a court must determine and announce on the record that a waiver is knowing and voluntary. In this case, we address how soon after a waiver colloquy such an announcement must be made, and whether that announcement may be combined with an announcement regarding a related colloquy.

FACTS AND LEGAL PROCEEDINGS

Petitioner, Devon Edward Morgan, was charged with two counts of possession of cocaine and two counts of distribution of cocaine, stemming from two separate…