Does a defendant have a right to withdraw his guilty plea if counsel declines to make the motion on his own behalf?

If counsel declines to make the motion, it does not follow that the defendant has a right to make a motion on his own behalf, or to demand that the court appoint substitute counsel. A defendant has a right either to counsel or to proceed pro se, Faretta v. California , 422 U.S. 806, 834, 95 S.Ct. 2525, 45 L.Ed.2d 562 (1975), but has no right to hybrid representation, in which he is represented by counsel from time to time, but may slip into pro se mode for selected presentations.⁵ See Clark v. Perez , 510 F.3d 382, 395 (2d Cir. 2008). And it is well settled that a defendant may not disrupt proceedings by demanding new counsel whenever he differs from his lawyer's strategic, legal, or ethical judgments about how to conduct a case. To hold that a defendant who wishes to withdraw his already-accepted guilty plea has a right to do so with the assistance of counsel would either require defense counsel to make motions they regard as frivolous, or require district courts to appoint new counsel for that purpose in every case in which a defendant has buyer's remorse about having accepted a plea agreement.