State v. Braswell

Summary

The court held that the trial court improperly denied the defendant’s clear request for self-representation by focusing on the adequacy of appointed counsel and the status of discovery rather than determining whether the defendant’s waiver of counsel was knowing and intelligent. The defendant’s conduct did not forfeit the right because it was not sufficiently disruptive before the denial, and later conduct could not cure the prior ruling. The court further held that a clear and conclusive denial of self-representation is structural error not subject to harmless-error analysis, and therefore affirmed the Appellate Court’s reversal and remand for a new trial.