Womack v. State

Womack v. State, No. 2962, September Term, 2018. CRIMINAL LAW — WAIVER OF COUNSEL — KNOWING AND INTELLIGENT WAIVER The circuit court did not strictly comply with Rule 4-215 prior to appellant’s discharge of counsel, and despite the court’s attempt to fix the initial failure to comply with the Rule, subsequent advisements did not “cure” the initial error. Although advisements under Rule 4-215(a) may be given in a piecemeal fashion, compliance with the Rule must be established before a valid waiver. We are not suggesting that, if a trial court fails to strictly comply with Rule 4-215, the error…