What is the current state of the law on retained counsel in civil litigation?

"In view of the importance of [the defendant's rights to retain and discharge counsel of his choice] and the severe consequences which flow from their violation, the trial courts are required to 'make all reasonable efforts to ensure that a defendant financially able to retain an attorney of his own choosing can be represented by that attorney.' (People v. Crovedi [(1966)] 65 Cal.2d [199,] 207.) To this end, 'the state should keep to a necessary minimum its interference with the individual's desire to

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defend himself in whatever manner he deems best, using any legitimate means within his resources . . . .' (Id. at p. 208.)" (People v. Courts (1985) 37 Cal.3d 784, 790.)

"Because the right to discharge retained counsel is broader than the right to discharge appointed counsel, a Marsden-type hearing at which the court determines whether counsel is providing adequate representation or is tangled in irreconcilable differences with the defendant is '"[an] inappropriate vehicle in which to consider [the defendant's] complaints against his retained counsel."' [Citations.]" (People v. Keshishian (2008) 162 Cal.App.4th 425, 429.)