State v. SurianoAnnotate this Case
Defendant was charged with obstructing an officer. The State Public Defender (SPD) appointed a lawyer. Thereafter, three appointed attorneys withdrew in rapid succession. The circuit court determined that Defendant had forfeited his right to appointed counsel, and the SPD denied Defendant’s request for a fourth attorney. Defendant represented himself at the one-day trial, and the jury found him guilty of obstruction. The court of appeals affirmed. The Supreme Court affirmed, holding (1) right-to-counsel warnings in forfeiture cases and the procedures suggested by the dissent in State v. Cummings are strongly recommended but not required; and (2) after applying the standard enunciated in State v. Cummings to this case, it is clear that Defendant forfeited his constitutional right to counsel by engaging in voluntary and deliberate conduct that frustrated the progression of his case and interfered with the proper administration of justice.