Supreme Court of North Carolina
State v. Harvin
November 4, 2022
Summary
The Court held that defendant did not forfeit his constitutional right to counsel because his conduct was not sufficiently egregious, obstructive, or dilatory to justify requiring him to proceed to trial pro se. Defendant had remained respectful, had not seriously obstructed proceedings, and repeatedly requested appointed counsel when he became unable to represent himself effectively. The Court therefore affirmed the Court of Appeals’ decision vacating the convictions and ordered a new trial on all charges.