Broadwater v. State

Ironically, it is immeasurably easier to waive a fundamental protection of the United States Constitution than it is to waive a provision of the Maryland Rules. The latter, after all, are “precise rubrics.. that are to be read and followed,” Isen v. Phoenix Assurance Co., 259 Md. 564, 570, 270 A.2d 476 (1970), whereas the former are but the “majestic ambiguities” 1 written for the ages. An especially intimidating specimen of those “precise rubrics” are the three densely packed pages of Maryland Rule 4-215, dealing with the waiver of the right to counsel. They are stern directives far more…