State v. Jones, 220 N.C. App. 392

Jones was found guilty of second-degree murder in 2011 for the 2006 death of Sarah Slaton.
The prosecution originally charged Jones with first-degree murder, triggering a lengthy defense history.
Multiple lawyers served as appointed and standby counsel as Jones at times proceeded pro se.
In 2009 Jones moved to represent himself and a mistrial resulted.
In 2010 Paramore served as standby and then was removed; Gerrans was appointed as new counsel.
In November 2010 Jones waived counsel, was found competent, and proceeded pro se at retrial, leading to the 2011 conviction and sentence of 300–369 months.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court erred by not instructing counsel to defer to Jones’s wishes.	Jones argues Ali required deferring to his wishes on trial strategy.	Jones contends counsel should have pursued his theories of misconduct.	No error; counsel were ethically barred from pursuing frivolous claims; trial court did not need to defer.
Whether Jones’s waiver of counsel was valid.	Ali-based objections aside, waiver complied with 15A-1242.	Waiver was invalid due to misadvice under Ali.	No error; court complied with 15A-1242 standards and properly accepted the waiver.

State v. Ali, 329 N.C. 394 (1991) (attorney must comply with client’s lawful instructions; frivolous claims not required)
State v. Tate, 187 N.C.App. 593 (2007) (de novo review of constitutional rights)