Bolden v. State

Summary

The Court held that a trial court must resolve defense counsel’s motion to withdraw before addressing a defendant’s motion to withdraw a plea. Because the Superior Court instead required Bolden to pursue plea withdrawal without counsel and without a valid waiver, it violated his constitutional right to counsel at a critical stage. The Court reversed Bolden’s convictions and sentence and remanded with instructions to reinstate the no-contest plea and appoint substitute counsel.