State v. Cureton Even if defendant’s IQ (82) and his past mental problems placed him in the “gray area” of defendants under Dusky v. United States, 362 U.S. 402 (1960) -- those who are competent to stand trial but may not be competent to represent themselves – neither U.S. Supreme Court precedent nor N.C. law prohibits a trial court from finding that a gray-area defendant has forfeited his right to counsel through his abusive actions toward his appointed attorneys.
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