A capital murder defendant's waiver of counsel was knowing and voluntary because he responded affirmatively to the judge's inquiry and a psychiatrist opined that he did not appear to have a serious mental disorder. The Supreme Court of North Carolina disregarded the significance of his claims to be Lucifer and the psychiatrist's opinion that he appeared hypomanic with characteristics of a personality disorder.

The trial judge granted the defendant's request for waiver of counsel and the trial proceeded. The defendant was found guilty of murder. At the sentencing hearing, he called the jurors "antichrists' and told them they could "kiss his natural black ass in the window of "Heilig-Meyers" and they could "pull the switch and let the good times roll". He also warned the jurors that he would meet them in hell, where they would be required to worship him. The jury sentenced him to death.

On appeal, the defendant argued that his berating of the jurors at the sentencing hearing was tantamount to legal suicide and the trial court should have terminated his right to self-representation and assigned counsel. The Court disagreed, relying on precedent that "If the defendant because of his conduct lost his right of self-representation, he was not prejudiced when the court did not enforce this rule against him."

The Appeals Court determined that the citizens of Virginia had a First Amendment "right to know that the incompetent are not tried and that the competent do not evade trial." The government's interest in preserving the defendant's right to a fair trial might be impaired by adverse publicity, the mere "risk of prejudice does not automatically justify refusing public access." Also, the right of access included documents filed in connection with the hearing.

The Court also reiterated its previous position that no physician-patient confidentiality privilege existed in criminal proceedings. The defendant presented no testimony or evidence in support of his arguments, and the newspaper's writ of mandamus was granted.