In what circumstances will a judge grant a Marsden hearing for a motion for a new trial based on incompetent counsel?

In any event, Reed is legally and factually distinguishable. The issue in Reed was whether the trial court made the inquiry necessary to assess the defendant's motion for new trial based on incompetent counsel. (People v. Reed, supra, 183 Cal.App.4th at pp. 1143-1144.) After other unsuccessful Marsden motions, the Reed defendant asked to pursue a motion for new trial based on counsel's incompetence, and defense counsel said, "I cannot make it for him." (Id. at p. 1142.) Reed made it sufficiently clear that he was in fact requesting substitute counsel to pursue the motion for new trial. (Id. at pp. 1145-1146.) Therefore, the Reed court found that a Marsden hearing was required.