STATE v. BROWN

No. 65, Sept. Term, 1995.

676 A.2d 513 (1996)

342 Md. 404

STATE of Maryland v. Shawn L. BROWN.

Court of Appeals of Maryland.

May 17, 1996.


Attorney(s) appearing for the Case

M. Jennifer Landis, Asst. Atty. Gen. (J. Joseph Curran, Jr., Atty. Gen., on brief), Baltimore, for Petitioner.

Claudia A. Cortese, Asst. Public Defender (Stephen E. Harris, Public Defender, on brief), Baltimore, for Respondent.

Argued before MURPHY, C.J., and ELDRIDGE, RODOWSKY, CHASANOW, KARWACKI, BELL and RAKER, JJ.


RAKER, Judge.

In this case, we are asked to determine whether Maryland Rule 4-215, which outlines the procedures a trial court must follow when a defendant elects to discharge counsel, applies to decisions to dismiss counsel made after the trial has begun. We shall hold that the Rule does not apply after trial proceedings have commenced.

I.

On October 26, 1993, two undercover police officers purchased $20...

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