State v. Joiner, 237 N.C. App. 513 (Dec. 2, 2014)

The court rejected the defendant’s argument that the trial court failed to make the proper inquiry required by G.S. 15A-1242 before allowing him to proceed pro se, concluding that the defendant’s actions “absolved the trial court from this requirement” and resulted in a forfeiture of the right to counsel. As recounted in the court’s opinion, the defendant engaged in conduct that obstructed and delayed the proceedings.