WHICHARD, Justice.
Defendant was tried capitally for the first-degree murder of Debra Ann Proctor. Immediately before jury selection, the trial court conducted a hearing on the issue of defendant's representation by counsel and ruled that defendant could proceed pro se. After a trial in which defendant did not present evidence, the jury convicted him of first-degree murder on the theory of premeditation and deliberation. At the penalty phase, the State presented...
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