Gambrill v. State

We confront here the question of whether a trial judge had a duty to engage in a Rule 4-215(e) colloquy1 with Michael *294Gambrill, Petitioner, when his public defender, on the day of trial, stated: ‘Your Honor, on behalf of Mr. Gambrill, I’d request a postponement. He indicates that he would like to hire private counsel in this matter.” We shall determine that the judge could have reasonably concluded from these statements that Gambrill wanted to discharge his attorney and, thus, erred in failing to permit Gambrill to explain the reasons for his request to discharge counsel, as required by Rule…