Maurice Williams, Below-Appellant v. State of Delaware, Below-Appellee

Summary

The court reversed Williams's conviction because the trial judge denied his mid-trial request to represent himself without conducting any colloquy or weighing the defendant's interests against disruption to the proceedings. The court held that beginning trial with appointed counsel, without more, does not justify denying self-representation, and that denial of this structural constitutional right is not subject to harmless-error review. The court did not reach Williams's separate challenge concerning the justification defense.