What is the standard of review for a motion to relieve a retained attorney?

California, United States of America


The following excerpt is from People v. Thierry, B261839 (Cal. App. 2016):

Defendant argues the record contains undisputed evidence of judicial bias (citing Briggs v. Superior Court (2001) 87 Cal.App.4th 312, 319 [de novo standard of review applies to questions of law where the facts are not in dispute]). He argues, for example, that the trial court gave a false explanation for applying the Marsden standard to his request to relieve his retained attorneythat it believed his attorney was appointed; conducted an unnecessary inquiry into the timeliness of his request for appointed counsel;

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