State v. Cash

Appellant appeared pro se before the trial court and was convicted of third degree criminal sexual conduct. The record fails to show that the trial judge made any finding that appellant’s decision to proceed pro se was accompanied by a knowing and intelligent waiver of his right to counsel. Appellant, therefore, contends he is entitled to a new trial. We disagree.

It is the responsibility of the trial judge to conduct a hearing to determine whether an accused’s request to proceed pro se is accompanied by a knowing and intelligent waiver of the right to counsel. State v. Coto, 296 S.C. 480, 374…