State v. Graham

WHICHARD, Judge.

Defendant contends the court erred in denying him court-appointed counsel or additional time in which to secure retained counsel. We find State v. McCrowre, 312 N.C. 478, 322 S.E. 2d 775 (1984), controlling. Pursuant thereto, we hold that in the absence of (1) further inquiry into the reason(s) for defendant’s lack of counsel and (2) the inquiries required by N.C. Gen. Stat. Sec. 15A-1242 (1983), it was error to require defendant to proceed to trial pro se.

The pertinent facts are as follows:

Defendant initially requested and received court-appointed counsel. On 1 June 1983, by…