State v. Wray, 228 N.C.App. 504, 747 S.E.2d 133 (Aug. 6, 2013)

The trial court did not err by failing to appoint counsel for the defendant after his case was remanded from the appellate division and before ordering the defendant to submit to a capacity to proceed evaluation. The court held: “the trial court’s order committing defendant to a competency evaluation was not a critical stage and defendant was not denied his Sixth Amendment right to counsel.”