Right to Counsel

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Indigent defendants

People v. Washington (2019) 34 Cal.App.5th 311

McCoy v. Louisiana (2018) 138 S.Ct. 1500

People v. Bernal, H045620, 12/5/19 The client's disagreement with counsel must be part of the record.

People v. Palmer; D074240; 5/22/20; C/A 4th, Div. 1

In re Smith; E073871; 5/26/20; C/A 4th, Div. 2

Marsden motion to substitute appointed counsel

"[T]he court must allow the accused to give specific reasons why he wishes replacement of his appointed counsel. (People v. Montiel (1993) 5 Cal.4th 877, 906, disapproved on other grounds in People v. Sanchez (2016) 63 Cal.4th 665, 679.) But court doesn't have a sua sponte duty.

"[M]erely express[ing] some unhappiness with certain aspects of counsel's handling of his case" is not a Marsden hearing request. (People v. Wright (1990) 52 Cal.3d 367, 410, disapproved on other grounds in People v. Williams (2011) 49 Cal.4th 405.)