People v. Lesley

Court erred in denying Defendant, in postconviction proceeding, his right to appointed counsel if his misconduct toward counsel continued, without first warning Defendant. Thus, Defendant's repeated failure to cooperate with his appointed counsel was not a knowing waiver. Although court was within its discretion not to permit defense counsel to withdraw immediately, court erred by permitting counsel to withdraw before warning Defendant that he risked losing his right to appointed counsel if his behavior continud. (McDADE, concurring; SCHMIDT, dissenting.)