State v. Mee, 233 N.C.App. 542, 756 S.E.2d 103 (Apr. 15, 2014)

The defendant forfeited his right to counsel where he waived the right to appointed counsel, retained and then fired counsel twice, was briefly represented by an assistant public defender, repeatedly refused to state his wishes with respect to representation, instead arguing that he was not subject to the court’s jurisdiction, would not participate in the trial, and ultimately chose to absent himself from the courtroom during the trial. The court rejected the defendant’s argument that he should not be held to have forfeited his right to counsel because he did not threaten counsel or court personnel and was not abusive. The court’s opinion includes extensive colloquies between the trial court and the defendant.