Holt v. State, 182 A.3d 322

On March 30, 2016, two groups (the Holt group and the Thornton group) confronted one another at Fort Cumberland Homes; shots were fired but no one was hit. Holt was charged with attempted first-degree murder, first-degree assault, conspiracy, and related counts.
Earlier that day Holt had an altercation with Malachi Thornton; later Holt and associates returned to the Homes at night after learning the Thorntons were looking for them.
A handwritten, signed letter from Holt stating “I no longer wish you to represent me and I am going to have to discharge you” was attached to counsel’s motion to withdraw before trial.
At a July 22 status hearing, the court recognized Rule 4-215(e) applied but deferred resolution; at a July 26 hearing defense counsel told the court that Holt had withdrawn his request and wanted counsel to proceed to trial. Trial proceeded with counsel.
Defense requested a jury instruction on imperfect self-defense (voluntary manslaughter theory). The trial court refused the instruction; Holt appealed arguing (1) the court failed to comply with Rule 4-215(e) and (2) the court erred in denying the imperfect self-defense instruction.
The Court of Special Appeals affirmed: Rule 4-215(e) inquiry was not required after counsel represented Holt had withdrawn the discharge request; Holt failed to produce “some evidence” of subjective belief of imminent danger and non- aggressor status necessary for imperfect self-defense.

Issue	Holt's Argument	State's Argument	Held
Whether court erred under Md. Rule 4-215(e) by not conducting an inquiry into Holt’s written request to discharge counsel	Holt: the handwritten letter and conflicting proffers from officers of the court created ambiguity requiring the court to inquire of Holt directly	State: Holt, through counsel, withdrew the request; counsel’s statement that Holt wanted representation resolved the matter and no further inquiry was required	Court: No error — counsel’s statement that Holt withdrew the request was the operative, last word, so Rule 4-215(e) inquiry was not required
Whether the court erred by refusing an imperfect self-defense jury instruction	Holt: evidence (prior encounter where a gun was brandished, the Thornton group allegedly armed with a bat/knife, and the nighttime return) supported a reasonable inference of Holt’s subjective belief of imminent harm and that he was not the aggressor	State: Holt produced no evidence of his subjective belief at the moment shots were fired and was an aggressor (he went to the fight) — so no instruction warranted	Court: No error — Holt failed to produce “some evidence” of (1) a subjective honest belief of imminent death/serious harm at the time of shooting and (2) non-aggressor status; instruction properly denied

Garner v. State, 414 Md. 372 (2010) (trial court may rely on defense counsel’s statement that client wants counsel to remain when that is the last word to the court)
State v. Davis, 415 Md. 22 (2010) (any statement reasonably apprising the court that defendant wishes to discharge counsel triggers Rule 4-215(e); inquiry required when defendant’s present intent to seek new counsel is indicated)
Williams v. State, 435 Md. 474 (2013) (defendant’s clear present-intent letter to discharge counsel triggers Rule 4-215(e); court must promptly determine whether intent persists)
Martin v. State, 329 Md. 351 (1993) (to warrant imperfect self-defense instruction, there must be some evidence that the defendant’s subjective belief of imminent danger existed at the time of the shooting)
Roach v. State, 358 Md. 418 (2000) (written or other evidence of defendant’s subjective belief can suffice to generate imperfect self-defense issue)
Faulkner v. State, 301 Md. 482 (1984) (differentiates perfect and imperfect self-defense; imperfect self-defense requires only the defendant’s honest subjective belief)