NYCA found that, although the trial court recognized that Mr. H had made an unequivocal request to proceed pro se, the court thereafter failed to conduct the required “‘searching inquiry’ to ensure that the defendant’s waiver [of the right to counsel] is knowing, intelligent, and voluntary.” NYCA disagreed with the Appellate Division, which had found that Mr. H had withdrawn an equivocal request by agreeing with the court that self-representation would be undesirable. CAL attorney Megan Bryne represented Mr. H on appeal.