Does a defendant have a right to discharge or substitute counsel at trial if they are not represented by appointed counsel?

MultiRegion, United States of America

The following excerpt is from Peavy v. Madden, Case No.: 19cv0743-MMA (BGS) (S.D. Cal. 2020):

2. People v. Marsden, 2 Cal.3d 118, 123 (1970) (holding that defendants represented by appointed counsel may discharge their attorneys and substitute new counsel if their right to counsel would be substantially impaired by continuing with the original attorney).

3. Faretta v. California, 422 U.S. 806, 807 (1975) (holding that a criminal defendant has a federal constitutional right to proceed without counsel when he voluntarily and intelligently elects to do so).

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