Melvin D. Williams v. State of Maryland
Court of Appeals, Harrell, Filed Nov. 22, 2013,
Discharge of Counsel- When the defendant makes ANY statement from which a court COULD conclude reasonably that the defendant MAY be inclined to discharge counsel, Rule 4-215(e) is triggered. Once triggered, the trial court has an affirmative duty to address the defendant’s request, including inquiry into the underlying reasons for the purported request to discharge counsel.

Defendant wrote a letter to the trial court on 1/27/2010 “to request New representation From the Public defender’s office. Pending me being able to afford an attorney.” The letter was never addressed on the record, and over the next 16 months, counsel remained unchanged. During this time, there were 4 hearings in circuit court and a two-day jury trial. At no point did the defendant raise the issue of retaining new counsel other than the letter.

Despite this seemingly obvious waiver of the issue, the Court of Appeals reversed and remanded for a new trial.

Other notes from the opinion:
Resisting Arrest – the force element of resisting arrest need not always constitute second degree assault against a law enforcement officer. Quoting Nicolas
Resisting Arrest – may be based on resistance of non-police-officer attempting to aid police in a valid arrest