State v. GarrisonÂ, 248 N.C. App. 729

Defendant Damon J. Garrison was indicted on drug-related charges and originally had court-appointed counsel.
Defense counsel moved to withdraw on July 17, 2014, stating the defendant wanted to "present the strategy;" the motion was allowed and defendant proceeded without counsel at trial.
The case was tried in Mecklenburg County Superior Court before Judge Linwood O. Foust in May 2015.
On May 8, 2015, the jury convicted defendant on all counts; sentence was suspended and twelve months supervised probation imposed.
Defendant appealed, arguing the trial court failed to make the mandatory inquiry under N.C. Gen. Stat. § 15A-1242 before permitting him to proceed pro se.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Garrison)	Held
Whether the trial court complied with N.C. Gen. Stat. § 15A-1242 before allowing defendant to proceed pro se	Conceded error as to failure to advise defendant of the range of permissible punishments; new trial warranted	Trial court failed to conduct the § 15A-1242 inquiry (not advised of rights, consequences, or punishment range)	Court held the trial court failed to satisfy § 15A-1242(3) (range of punishments); failure to perform mandatory inquiry is prejudicial error and requires a new trial

Godwin, 95 N.C. App. 565 (mandatory § 15A-1242 inquiry; failure is prejudicial error)
Stanback, 137 N.C. App. 583 (same; failure to conduct inquiry requires new trial)
Thomas, 331 N.C. 671 (trial court must ensure constitutional and statutory standards before allowing waiver of counsel)
Gideon v. Wainwright, 372 U.S. 335 (right to counsel in serious criminal matters guaranteed by the Sixth Amendment)