The State, Respondent v. Lamont Antonio Samuel, Petitioner.

Summary

The South Carolina Supreme Court held that the circuit judge erred by exceeding the scope of the Faretta inquiry when denying Lamont Antonio Samuel’s request to proceed pro se, because the judge considered third‑party testimony and alleged manipulation rather than focusing solely on whether the waiver was knowing, intelligent and voluntary. The Court reversed the appellate court’s affirmation and remanded for a new trial, emphasizing that competence to represent is irrelevant to the waiver inquiry.