What is the test for a motion to substitute counsel in a habeas proceeding?
MultiRegion, United States of America
The following excerpt is from Bland v. California Dept. of Corrections, 20 F.3d 1469 (9th Cir. 1994):
We review the trial court's refusal to substitute counsel for an abuse of discretion. United States v. Walker, 915 F.2d 480, 482 (9th Cir.1990). The denial of a motion to substitute counsel implicates the defendant's Sixth Amendment right to counsel, see id. at 485, and thus is properly considered in this habeas proceeding.
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