California, United States of America
The following excerpt is from People v. Chiprez, D067475 (Cal. App. 2015):
6. "Substantial impairment of the right to counsel can occur when the appointed counsel is providing inadequate representation or when 'the defendant and the attorney have become embroiled in such an irreconcilable conflict that ineffective representation is likely to result [citation].' " (People v. Clark (2011) 52 Cal.4th 856, 912.)
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