State v. Cureton, 223 N.C.App. 274, 734 S.E.2d 572 (Nov. 6, 2012)

No violation of the defendant’s Sixth Amendment right to counsel occurred when the trial court found that the defendant forfeited his right to counsel because of serious misconduct and required him to proceed pro se. The court rejected the defendant’s argument that Indiana v. Edwards prohibits a finding of forfeiture by a “gray area” defendant who has engaged in serious misconduct.