Webb v. State, 320 A.3d 239

William J. Webb, Jr. was convicted in Delaware Superior Court of several offenses including stalking, intimidation, criminal contempt, and breach of bond conditions, after a series of incidents involving his child's mother, Patricia Burgess, who had a no-contact order against him.
Webb went through multiple court-appointed attorneys, each of whom withdrew, citing Webb's threats of violence, harassment, and lawsuits against them.
The court ultimately determined Webb had to proceed without further appointed counsel due to this misconduct, and did not appoint standby counsel.
Webb chose to represent himself at trial and was convicted on all charges; he was sentenced as a habitual offender to 25 years imprisonment.
On appeal, Webb argued his right to counsel was violated because the court did not conduct a proper inquiry into whether he was waiving his right to counsel knowingly and intelligently.
The State argued, and the Superior Court found, that Webb forfeited his right to counsel by his egregious misconduct toward appointed lawyers.

Issue	Webb's Argument	State's Argument	Held
Did Webb's right to counsel require a proper colloquy before proceeding pro se?	The court forced Webb to proceed pro se without ensuring a knowing and intelligent waiver of counsel.	Webb forfeited his right to counsel through extremely serious misconduct, so no colloquy was required.	Webb forfeited his right to appointed counsel through threats and harassment; no colloquy was necessary.
Did the Superior Court abuse its discretion by refusing to appoint new or standby counsel?	Refusal to appoint new counsel constituted an abuse of discretion.	The refusal was justified due to Webb's conduct and multiple prior counsel withdrawals.	No abuse of discretion; the refusal was supported by the record and controlling law.

Bultron v. State, 897 A.2d 758 (Del. 2006) (forfeiture of right to counsel can occur through extremely serious misconduct, even absent violence or explicit threats)
United States v. Goldberg, 67 F.3d 1092 (3d Cir. 1995) (forfeiture of counsel does not require warnings or pro se advisals)