People v. Adkins

I agree with the majority’s statement of the controlling standard for appellate review of an alleged waiver of the right to counsel and assertion of the obverse right to self-representation. As described in the majority opinion, “substantial compliance” with People v Anderson, 398 Mich 361; 247 NW2d 857 *738(1976), and MCR 6.005(D)1 provides adequate protection of a defendant’s rights.2

I also agree with the majority’s application of this standard in People v Adkins. However, I dissent in People v Suggs because the majority fails to heed the threshold inquiry of a proper analysis.

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In assessing the…