California, United States of America
The following excerpt is from People v. Hemphill, H040140 (Cal. App. 2015):
substitute counsel would ' " 'substantially impair' the defendant's right to effective assistance of counsel." ' " (People v. Gutierrez (2009) 45 Cal.4th 789, 803.) We find the trial court made proper inquiries and did not abuse its discretion when it declined to substitute counsel.
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