State v. Brown

RAKER, Judge.

In this case, we are asked to determine whether Maryland Rule 4-215, which outlines the procedures a trial court must follow when a defendant elects to discharge counsel, applies to decisions to dismiss counsel made after the trial has begun. We shall hold that the Rule does not apply after trial proceedings have commenced.

I

On October 26, 1993, two undercover police officers purchased $20 worth of crack cocaine from a person they later identified as Respondent, Shawn L. Brown. The transaction was videotaped. On November 12, 1993, the officers purchased another $20 worth of crack…