Brye v. State

HARRELL, Judge.

This Court, in some recent cases, exhibited a degree of tolerance when examining the sufficiency of required advisements to a defendant before acceptance of a waiver of counsel where the totality of advisements was rendered accurately by a series of judges of the same tier of court in a case. See, e.g., Broadwater v. State, 401 Md. 175, 931 A.2d 1098 (2007); Gregg v. State, 377 Md. 515, 833 A.2d 1040 (2003). The present case exceeds that tolerance.

Maryland Rule 4-215(a)(3) provides that a defendant in a criminal case wishing to waive his or her right to counsel first be advised…