Can a motion to relieve a court-appointed attorney be denied without a hearing?

MultiRegion, United States of America

The following excerpt is from Biddle v. Brazelton, No. 2:12-cv-01119-JKS (E.D. Cal. 2014):

2. People v. Marsden, 465 P.2d 44 (Cal. 1970) (holding it was error for the trial court to deny a defendant's motion to relieve his court-appointed attorney without holding a hearing to allow the defendant to explain its grounds).

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