California, United States of America
The following excerpt is from People v. Brady, H045210 (Cal. App. 2018):
4. People v. Marsden (1970) 2 Cal.3d 118. "[A] trial court is obligated to conduct a Marsden hearing on whether to discharge counsel for all purposes and appoint new counsel when a criminal defendant indicates after conviction a desire to withdraw his plea on the ground that his current counsel provided ineffective assistance . . . when there is 'at least some clear indication by defendant,' either personally or through his current counsel, that defendant 'wants a substitute attorney.' " (People v. Sanchez (2011) 53 Cal.4th 80, 89-90.)
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