The following excerpt is from Azevedo v. Garofalo, No. 2:18-cv-2276 AC P (E.D. Cal. 2018):
3. Under People v. Marsden, 2 Cal. 3d 118, 123 (1970), a trial court must appoint substitute counsel for a criminal defendant if, absent such appointment, his Sixth Amendment "right to the assistance of counsel would be substantially impaired."
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