MICHAEL GAMBRILL v. STATE OF MARYLAND
Court of Appeals, Battaglia, Filed Feb. 27, 2014,
Discharge Counsel- When an ambiguous request to discharge counsel is presented, it is the duty of the court to conduct a Rule 4-215(e) colloquy nonetheless.

“Your Honor, on behalf of Mr. Gambrill, I’d request a postponement. He indicates that he would like to hire private counsel in this matter.”
This statement, while ambiguous as to the defendant’s intent, required that the trial court conduct a 4-215(e) colloquy to determine the basis (or existence) of the defendant’s request to discharge counsel.

Rule 4-215(e) states that “If a defendant requests permission to discharge an attorney whose appearance has been entered, the court shall permit the defendant to explain the reasons for the request” (emphasis added)

Other notes from the case:
Discharge Counsel- Neither payment to an attorney nor a fee agreement are necessary to evoke a Rule 4-215(e) colloquy