State v. Wilder — Defendant Who Refuses to Answer § 15A-1242 Inquiry Cannot Establish Knowing Waiver of Counsel
The North Carolina Court of Appeals held that a defendant who clearly invokes the right to self-representation but then refuses to answer any of the trial court’s N.C. Gen. Stat. § 15A-1242 questions cannot establish a knowing, intelligent, and voluntary waiver of counsel, and the trial court therefore did not err in denying the request to proceed pro se.