Tingle v. State

Summary

The Court affirmed Tingle’s convictions, holding that the Superior Court did not abuse its discretion by denying his eve-of-trial request to replace privately retained counsel. Tingle had stated his dissatisfaction, but he identified no facts showing good cause, had not previously complained, had ample opportunity to obtain new counsel, and sought a continuance that would delay trial. The Court also held that Tingle did not clearly and unequivocally invoke self-representation, so no separate waiver colloquy was required.