What is the test for substituting an attorney for a defendant in a civil case?
MultiRegion, United States of America
The following excerpt is from U.S. v. Spearman, 96 F.3d 1452 (9th Cir. 1996):
"A trial court may not summarily refuse to allow the substitution of attorneys, but must conduct 'such necessary inquiry as might ease the defendant's dissatisfaction, distrust, and concern.' " Id. (quoting Hudson v. Rushen, 686 F.2d 826, 829 (9th Cir.1982), cert. denied, 461 U.S. 916 (1983)).
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