In Re Watson, 209 N.C.App. 507, 706 S.E.2d 296 (Feb. 15, 2011)

(1) Because the trial court failed to comply with the statutory mandates of G.S. 15A-1242, 122C-268(d), and IDS Rule 1.6, the respondent’s waiver of counsel in his involuntary commitment hearing was ineffective. The court adopted language from State v. Moore, 362 N.C. 319, 327-28 (2008), endorsing a fourteen-question checklist for taking a waiver of counsel. The court also noted with approval language from an Arizona case suggesting the proper inquiry in involuntary commitment cases. (2) The fact that the respondent had standby counsel did not cure the improper waiver of counsel.