What is the test for making a substantial showing in a motion for inadequate representation?

California, United States of America


The following excerpt is from People v. Pena, 7 Cal.App.4th 1294, 9 Cal.Rptr.2d 550 (Cal. App. 1992):

(Id. at p. 220, 260 Cal.Rptr. 583, 776 P.2d 285; see also People v. Moore, supra, 47 Cal.3d 63, 252 Cal.Rptr. 494, 762 P.2d 1218 [defendant who claimed inadequate representation and expressed desire to control tactical decisions, failed to make the requisite "substantial showing"].)

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