Is it error for a trial court to deny a defendant's motion to relieve his court-appointed attorney without a hearing?

^1. See 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).

^2. Miranda v. Arizona, 384 U.S. 436 (1966).

^3. See Brecht v. Abrahamson, 507 U.S. 619, 639 (1993) (instructing that, where the standard applies, habeas relief is not warranted unless the error "had [a] substantial and injurious effect or influence in determining the jury's verdict").