California, United States of America
The following excerpt is from People v. Elder, F060101, Super. Ct. No. F09906153 (Cal. App. 2011):
The law does not support defendant's claim. While it is true, as a general proposition, that the relevant cases recognize that in some circumstances the relationship between a defendant and an attorney may be so broken that ineffective representation is likely to result (see, e.g. People v. Abilez (2007) 41 Cal.4th 472, 487-488), it is also true that cases granting relief on that basis are extremely rare.
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