Knox v. State

RAKER, Judge.

In this criminal case, we must interpret the language of Maryland Rule 4-215, Waiver of Counsel, and the meaning of the requirement of the Rule that the court shall “advise the defendant of the nature of the charges in the charging document, and the allowable penalties, including mandatory penalties, if any.” The question in this case is whether the mandatory penalties for a subsequent offender fall within the requirement of the Rule. We shall hold that they do and that such notice is required before a court may find that a defendant waives the right to be represented by counsel.

I