State v. Northam
Annotate this CaseAfter a jury trial, Kendall Northam was convicted of second degree murder and first degree assault. During the proceedings, Northam, who was represented by an assistant public defender, filed a pro se motion for change of venue that included a request for a court-appointed attorney. The motion was denied. On appeal, the court of special appeals held that Northam was entitled to a new trial on the ground that the circuit court had failed to comply with the requirements of Md. R. Crim. P. 4-215(e) by failing to permit Northam to explain the reasons for his request to discharge defense counsel. The Court of Appeals granted certiorari and reversed, holding that Northam waived his right to appellate review of the claim on the ground that he was not permitted to explain the reasons for requesting permission to discharge defense counsel.
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