State v. Westray

The question of how to deal with an indigent defendant who wishes to discharge his appointed counsel has bedeviled trial courts, as demonstrated by the many decisions of this Court and the Court of Special Appeals construing Maryland Rule 4-215(e), which governs the discharge of defense counsel. This Court recently had occasion to discuss application of the rule when the indigent defendant has a “meritorious” reason for discharge of an assistant public defender appointed to represent him. 1 This case concerns a parallel situation "with the exception that the trial court found that the…