Martin v. State

WILNER, Judge.

In Stevens v. State, 232 Md. 33, 192 A.2d 73, cert. denied, 375 U.S. 886, 84 S.Ct. 160, 11 L.Ed.2d 115 (1963), the Court of Appeals concluded that it was not “essential for the protection of a defendant’s constitutional rights that he be advised by the court of his right against self-incrimination when he is represented by counsel.” Id., 39, 192 A.2d 73. We said the same thing in State v. McKenzie, 17 Md.App. 563, 303 A.2d 406 (1973).

Both courts intimated, however, that where the defendant is proceeding without counsel, the trial court did have some duty in this regard. In…