245 N.C. App. 452 - State v. Blakeney’s Empirical Analysis

Citation profile

12 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “and specifically to cases in which the defendant engaged in one or more of the following: (1) flagrant or extended delaying tactics, such as repeatedly firing a series of attorneys; (2) offensive or abusive behavior, such as threatening counsel, cursing, spitting, or disrupting proceedings in court; or (3) refusal to acknowledge the trial court's jurisdiction or participate in the judicial process, or insistence on nonsensical and nonexistent legal”

   5 later decisions quote this exact passage
   e.g. 257 N.C. App. 195 - State v. Pena · 258 N.C. App. 516 - State v. Boderick

2. “'Once a defendant clearly and unequivocally states that he wants to proceed pro se , the trial court ... must determine whether the defendant knowingly, intelligently, and voluntarily waives the right to in-court representation by counsel.'”

   5 later decisions quote this exact passage
   e.g. 257 N.C. App. 195 - State v. Pena · 264 N.C. App. 753 - In re K.S.K.

3. “[D]efendant neither voluntarily waived the right to be represented by counsel, nor engaged in such serious misconduct as to warrant forfeiture of the right to counsel without any warning by the trial court. As a result, the trial court was required to inform defendant that if he discharged his attorney but was unable to hire new counsel, he would then be required to represent himself. The trial court was further obligated to conduct the inquiry mandated by N.C. Gen. Stat. § 15A-1242, in order to ensure that defendant understood the consequences of self-representation.”

   3 later decisions quote this exact passage
   e.g. 257 N.C. App. 195 - State v. Pena · 265 N.C. App. 325 - State v. Simpkins