Shawn Smith, Defendant Below, Appellant v. State of Delaware, Plaintiff Below, Appellee

Summary

The court held that Smith did not knowingly, intelligently, and voluntarily waive his Sixth Amendment right to counsel before representing himself at trial. Although Smith repeatedly expressed a desire to proceed pro se, the trial court did not conduct a sufficiently searching inquiry into the risks and consequences of self-representation or determine on the record that the waiver was valid. The judgments were reversed and the case was remanded for a new trial.