Brown v. State

ALPERT, Judge.

Appellant, Shawn L. Brown, was charged with two counts of distribution of cocaine and two counts of possession of cocaine. He was tried in the Circuit Court for Wicomico County on *742April 13,1994, and he was convicted on all counts. On May 6, 1994, appellant was sentenced to two consecutive terms of ten years each. This appeal followed, wherein appellant poses the-following question: “Did the trial court comply with the requirements of Maryland Rule 4-215 (waiver of counsel)?” To answer that question, we must determine whether the rule applies once the trial has commenced. We hold…