Harris v. State

BELL, Judge.

This case presents the issue of whether, after the Office of Public Defender (“OPD”) has been permitted to withdraw as counsel, a trial court may order, consistent with Md.Code (1957, 1993 Repl.Vol.1995 Cum.Supp.) Article 27A, the OPD to serve as standby counsel for a defendant, who it has found has voluntarily and knowingly waived his right to representation and elected to proceed pro se. The Circuit Court for Frederick County so ordered and the Court of Special Appeals, noting the trial court’s discretion to appoint standby counsel to avoid a “fractious, inefficient, and…