Supreme Court of Delaware

Muhammad v. State

January 20, 2022

Summary

The Court affirmed the judgment after concluding that the Superior Court did not violate Muhammad's right to self-representation by appointing counsel in either set of cases. Muhammad never clearly and unequivocally waived counsel in the Drug Cases, while his later statements reasserting a right to counsel and his inability to understand the charges and governing procedures justified reconsideration of his prior waiver in the Trafficking Case. The Court did not decide whether Muhammad's guilty pleas independently waived his self-representation claim.