WILLIAM WESTRAY v. STATE of MARYLAND
Court of Special Appeals, Kenney, Filed June 25, 2014,
Discharge of Counsel- A defendant seeking to discharge counsel must undergo a waiver inquiry before they can proceed pro se.

“I will represent myself and I would die first before I, before I, before I, before I come to court with this man, okay?”
With this understated declaration the defendant noted his intent to discharge counsel. The court, over several hearings, tried to convince the defendant not to discharge his counsel, noting that discharging his attorney would mean “defending yourself or you’re seeking to retain private counsel.”
This was insufficient to satisfy the CoSA, however, which held that Rule 4-215(e) required a full waiver of counsel inquiry as set forth in 4-215(a)(4).
In an extention of Valonis, the CoSA held that strict compliance with Rule 4-215 was required and that failure to do so mandated reversal.