What is the standard for discharging a retained attorney?

Defendant contends the trial court erred by denying his request to discharge his retained attorney and substitute a new retained attorney. According to defendant, the trial court applied the standard from People v. Marsden (1970) 2 Cal.3d 118 (Marsden) to determine whether the attorney-client relationship had deteriorated so much that counsel should be relieved. This standard does not apply to a request to substitute one retained attorney for another, and defendant argues the trial court's denial of the request violated his right under the Sixth Amendment to the United States Constitution to retain competent representation of his own choice. We find no error.

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1. Additional Background.