California, United States of America
The following excerpt is from In re J.M., C058919 (Cal. App. 4/8/2009), C058919 (Cal. App. 2009):
We agree with the juvenile court's conclusion. Based on the record before it, the court's implicit determination that the conflict between appellant and her trial counsel was not irreconcilable was well within its discretion. (Cf. People v. Fierro (1991) 1 Cal.4th 173, 204.) The record reflects that difficulties with communication existed, but they did not appear to be irreconcilable. The fact that appellant later moved successfully to represent herself does not undermine our conclusion, as that was a separate matter which appellant has not challenged in this appeal.
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