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Criminal Practice – Constitutional – Right to Counsel – Waiver – Insufficient Colloquy (access required)

State v. Pena (Lawyers Weekly No. 011-395-17, 23 pp.) (Donna Stroud, J.) Appealed from Mecklenburg County Superior Court (Robert Sumner & Eric Levinson, JJ.) N.C. App. Holding: Where a hearing transcript reveals that one judge failed to conduct a sufficient colloquy before allowing defendant to proceed pro se, and where the trial transcript is inadequate to ...

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