Commonwealth v. Gibson

The principal issue in this appeal is whether a Superior Court judge properly ordered the forfeiture of the defendant’s right to counsel in a probation revocation hearing. The judge, faced with a defendant who admittedly had engaged in a pattern of quarrelsome, confrontational, hostile, and threatening conduct toward a succession of nine different court-appointed attorneys over the course of the trial and posttrial proceedings, ordered forfeiture on those grounds. Subsequent to the forfeiture order, the defendant appeared pro se at the probation revocation hearing. A different judge found the…