EARL SYLVESTER COUSINS v. STATE OF MARYLAND
Court of Special Appeals, Arthur, Feb. 1, 2017,
Sixth Amendment- A defendant filing a grievance against their court-appointed attorney does not automatically entitle them to a new one
JOSEPH RUSSELL GEAR v. STATE OF MARYLAND
Court of Appeals, Per Curiam, Filed April 25, 2016,
Vacated and remanded unreported CoSA opinion for reconsideration under State v. Graves.
Doubling down on the proposition that while attorneys may act as agents for the defendant, they may not do so in a situation where the defendant seeks to discharge counsel without the court speaking to the defendant directly.
STATE OF MARYLAND v. JERIKO GRAVES
Court of Appeals, Hotten, Filed April 22, 2016,
Discharge of Counsel – Where a defendant is not directly asked “why do you want to discharge your attorney?” and the reasons for the request instead come from defense counsel, then the defendant must be consulted on the record concerning those reasons. Otherwise, reversal for failure to strictly comply with Rule 4-215.
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