People v. Lewis

Summary

The Court held that defendant knowingly waived his right to effective assistance of counsel through repeated obstructive conduct, including refusing substitute counsel, refusing self-representation, directing counsel not to participate, and repeatedly leaving the courtroom despite warnings. The Court also held that consecutive sentences for simple possession and possession with intent to use were unlawful because both offenses arose from the same act of possessing the firearms. The Appellate Division order was modified to require concurrent sentences on the paired weapon-possession counts and was otherwise affirmed.