Fowlkes v. State

ROBERT M. BELL, Judge.

This case presents for review a trial judge’s ruling, pursuant to Maryland Rule 4-215, that Jeffrey Fowlkes, a/k/a Anthony Johnson, appellant, who had discharged his counsel, represent himself at trial. We find no error; therefore, we will affirm.

Effective July 1, 1984, the Court of Appeals promulgated Maryland Rule 4-215, Waiver of Counsel, which included subsection (d), as follows: 1(d) Discharge of counsel—Waiver.—If a defendant requests permission to discharge an attorney whose appear anee has been entered, the court shall permit the defendant to explain the reasons…