Commonwealth v. El

OPINION BY

KELLY, J.:

¶ 1 Appellant, Khaddfi El, appeals the judgment of sentence of 11/é to 23 months’ imprisonment entered in the Philadelphia County Court of Common Pleas following his non-jury conviction of possession with intent to deliver a controlled substance. 1 We hold that the decision to reject without inquiry a request to proceed pro se made after the defendant’s jury-waiver colloquy has been completed rests within the trial court’s discretion. We also note that probable cause exists to search a suspect incident to an arrest when a trained and experienced narcotics officer observes…