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

California, United States of America


The following excerpt is from People v. Crandell, 251 Cal.Rptr. 227, 46 Cal.3d 833, 760 P.2d 423 (Cal. 1988):

During proceedings in superior court defendant for the first time requested substitute counsel. After much inquiry and discussion the court denied the request for appointment of substitute counsel, as well as defendant's requests for appointment of advisory counsel. Defendant contends that the requirements of People v. Marsden, supra, 2 Cal.3d 118, 84 Cal.Rptr. 156, 465 P.2d 44, were not satisfied, that he did not receive adequate warnings about the dangers of self-representation, that the court erred in not appointing advisory counsel, and that his ejection from a pretrial hearing made it an improper ex parte proceeding.

1. Facts

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