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To reverse the denial of a request to appear pro se, an appellate court must determine whether the pro se party’s request was effectively granted by the trial court. All courts are allowed to exercise their own discretion in granting or denying the right to proceed pro se, so long as the decision is supported by the record. While grant of the request to appear pro se is discretionary, courts must allow for a defendant who has pled guilty or nolo contendre to defend against a sentence of life imprisonment without parole. Nevertheless, the “right to self representation in criminal proceedings is a right that must be zealously protected, but not uncritically promoted.”

Accordingly, this Court has held that a trial court’s failure to allow a defendant to proceed pro se is reversible error if the defendant shows he was prejudiced by the court’s error. See State v. Thompson, 279 N.C. 277, 182 S.E.2d 375 (1971). Similarly, this Court has applied the Chapman “harmless error” test to determine whether a defendant was prejudiced when the trial court denied a pro se request to compel another inmate to testify. See State v. Burton, 119 N.C. App. 213, 216, 457 S.E.2d 858,

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Our analysis of clinical topics focuses on a few specifically selected issues of moral concern, such as euthanasia, who should have access to the technology, and who will benefit. To some extent, these issues have often required extensive reflection on the part of the caregiver. We refer to this kind of analysis as “hot-button” because it is, to varying degrees, “polarized” by a public that appears to be clamoring for a resolution. We have called this a hot-button issue because the caregivers initially recognize the need to address it, the issue becomes “hot” at an earlier stage of reflection because caregivers perceive that they must choose between two vocations-their “vocations,” in a sense, represent their moral identity. Then, after a period of reflection, the caregivers may realize that they are unable to resolve the issue. The caregivers experience a sense of abandonment, and the issue moves from the hot to the “cold” stage.
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