People v. Adkins

In People v. Adkins (After Remand), 452 Mich 702, 720; 551 NW2d 108 (1996), the Supreme Court specifically concluded that the trial court's failure to inform the defendant of the possible punishment available if he was convicted did not constitute an error requiring reversal of his conviction. Id. at 730-731. The Supreme Court noted that the trial court's previous efforts to inform the defendant that the charges were serious only reinforced its conclusion that the compliance, although clearly not full, was sufficient. However, the Court did not rest its conclusion on this one factor. Id. at 731. The Court held that a valid waiver of the right to counsel needs only substantial compliance with the requirements of Anderson and MCR 6.005. Substantial compliance occurs if "the court discusses the substance of both Anderson and MCR 6.005(D) in a short colloquy with the defendant and makes an express finding that the defendant fully understands, recognizes, and agrees to abide by the waiver of counsel procedures." Adkins, supra at 726-727.