California, United States of America
The following excerpt is from People v. Cox, B232769 (Cal. App. 2013):
so arbitrary as to violate due process, the reviewing court looks to the circumstances of each case, '"particularly in the reasons presented to the trial judge at the time the request [was] denied."' [Citations.]" (Id. at p. 791.) "'"The right to counsel cannot mean that a defendant may continually delay his day of judgment by discharging prior counsel,"' and the court is within its discretion to deny a last-minute motion for continuance to secure new counsel. [Citation.]" (People v. Keshishian (2008) 162 Cal.App.4th 425, 429.)
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