Appellant engaged in a pattern of serious misconduct, violence, and threats of violence against a succession of court-appointed attorneys. The trial court found that appellant had forfeited his right to counsel at a hearing in which his attorney not only did not represent his interests, but also argued against him. The appellate court here reversed and remanded. An accused may forfeit his right to counsel by a course of serious misconduct towards counsel, where lesser measures to control the defendant are insufficient to protect counsel and where appointment of successor counsel would be futile. In rare cases, lesser measures are not necessary where the misconduct is so serious that lesser measures would be patently inadequate. Forfeiture of counsel should only be a last resort and can only occur after a hearing at which a defendant is afforded full due process protections, including the assistance of counsel.