The People, Plaintiff and Respondent v. Daniel Loreto Noriega, Defendant and Appellant

Summary

The court held that replacing defendant's appointed public defender with another appointed attorney did not violate either the federal or California constitutional right to counsel. Although the replacement was an abuse of discretion under state statutory law because the trial court failed to advise defendant adequately about the potential conflict and available alternatives, reversal was unwarranted absent a reasonable probability that the error affected the trial's outcome. Justice Werdegar, dissenting, would have held that the removal violated the California Constitution because the asserted conflict was minor and did not justify disrupting the established attorney-client relationship.