State v. Joiner, 237 N.C.App. 513, 767 S.E.2d 557 (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.