People v. Brooks

Defendant appealed from his conviction for unlawful possession of methamphetamine arguing that he appeared pro se at critical states of the proceedings without a valid waiver of counsel. The appellate court vacated and remanded, finding that defendant appeared pro se at multiple stages during the proceedings without a valid waiver of counsel and that these were critical stages of the proceedings because defendant provided the State with potentially incriminating statements for “seemingly no legitimate strategic purpose” and defendant was required to provide discovery to the State. (ALBRECHT and DAVENPORT, concurring)