California, United States of America
The following excerpt is from People v. Sanford, C078614 (Cal. App. 2020):
abused its discretion, we consider whether it made an adequate inquiry into the defendant's complaints. (People v. Mungia (2008) 44 Cal.4th 1101, 1127-1128.)
Initially, defendant did not clearly indicate that he wanted to discharge Schlueter; instead, defendant agreed to the appointment of Davenport to consider the filing of a motion for a new trial. A defendant must make a clear indication that he or she is requesting a substitute attorney. (People v. Dickey (2005) 35 Cal.4th 884, 920) In any event, the court did hold a Marsden hearing on February 6, 2015, after defendant clearly requested one.
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