State v. Poole

In State v. Poole, 305 N.C. 308, 311-12, 289 S.E.2d 335, 338 (1982), the Supreme Court held that the trial court had conducted a sufficient inquiry into the defendant's complaint of ineffective assistance of counsel and request for substitute counsel despite the fact that the trial court did not "conduct an extensive inquiry and make findings of fact." The Supreme Court reasoned that the trial court did not need to inquire into defense counsel's legal experience or the amount of trial preparation because "the very manner in which defense counsel handled the pre-trial, trial, and post-trial proceedings was sufficient to give the trial court sufficient indication of defense counsel's ability." Id. at 313, 289 S.E.2d at 339.