Goodrich v. State – Maryland Supreme Court Opinion Date: October 24, 2025

Areas of Law: Constitutional Law, Criminal Law

This case involved Mr. Goodrich who was charged with attempted first-degree murder and related offenses in the Circuit Court for Montgomery County, Maryland. Before trial, both the defense and prosecution jointly requested a postponement of the trial date due to the resignation of the defendant’s public defender and the need for additional preparation time. The Defendant’s new counsel told the court that the defendant wanted to represent himself and keep the original trial date. The defendant told the court that he wanted an attorney but did not want the trial postponed, demanded a speedy trial and told the court he did not want to continue to be incarcerated.

The court ended up postponing the trial date, and the defendant did not request to discharge his attorney or to represent himself after that. At trial, the defendant was represented by counsel and was convicted by a jury of attempted second-degree murder, armed robbery, and use of a firearm in the commission of a felony or crime of violence.  This conviction was upheld by the Appellate Court of Maryland.  Their holding was that that the defendant had not expressed an intent to discharge his lawyer or to represent himself after the first continuance was granted, and that the trial court had provided him ample time to express his wishes.

The Supreme Court of Maryland reviewed whether the trial court violated the defendant’s constitutional and procedural rights by not conducting any further hearings on the question. The Supreme Court held that when a court is informed that a defendant might wish to represent himself, it must conduct a reasonable inquiry to determine if the defendant clearly and unequivocally asserts that right and must allow the defendant to explain his reasons for discharging counsel under Maryland Rule 4-215(e). However, if the defendant does not express a clear desire for self-representation or to discharge counsel, the court is not required to question him further. The Supreme Court affirmed the lower court’s judgment.