What is the test for a motion to substitute counsel for a defendant in a criminal case?

The failure of a trial court to give a defendant the opportunity to discuss the reasons for seeking a change in representation has also been examined in another context. In People v. Marsden (1970) 2 Cal.3d 118, 84 Cal.Rptr. 156, 465 P.2d 44, the appellant challenged the trial court's denial of his motion to substitute counsel without giving him the opportunity to state the reasons for his request. The court reversed the appellant's conviction. In doing so, the court stated that although it was within the trial court's discretion whether to grant the motion, a trial court could not intelligently exercise this discretion

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"[A] judge who denies a motion for substitution of attorneys solely on the basis of his courtroom observations, despite a defendant's offer to relate specific instances of misconduct, abuses the exercise of his discretion to determine the competency of the attorney. A judicial decision made without giving a party an opportunity to present argument or evidence in support of his contention is lacking in all the attributes of judicial determination." (People v. Marsden, supra, 2 Cal.3d at p. 124, 84 Cal.Rptr. 156, 465 P.2d 44.)