Is there an abuse of discretion when a defendant is denied a motion to appoint a new counsel?

California, United States of America


The following excerpt is from People v. Memro, 11 Cal.4th 786, 12 Cal.App.4th 783, 47 Cal.Rptr.2d 219, 905 P2d 1305 (Cal. 1995):

Defendant contends that the court erred each time it denied his motion to appoint new counsel. He maintains that there was a "complete and utter breakdown of the attorney client relationship" occasioned by counsel's failure to "contact material witnesses [905 P.2d 1343] regarding the pre-trial motions" and to prepare his case in a timely manner.

[11 Cal.4th 857] We review the court's rulings for an abuse of discretion. (People v. Berryman

Page 257

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