ALBANY – A robbery defendant who fired his attorney and represented himself was denied his right to counsel because the trial judge failed to undertake the “searching inquiry” required before an accused can proceed pro se, the Court of Appeals held yesterday.
People v. Michael Arroyo, 64, was one of two cases in which the Court was called upon to clarify the extent of inquiry necessary before a judge may permit a defendant to exercise the right of self representation. In Arroyo, the Court reversed the second-degree robbery conviction. However, it affirmed Charles Lineberger’s conviction for first-degree robbery in People v. Charles Lineberger, 65.
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