California Supreme Court

People v. Johnson

March 14, 2019

Summary

The court modified its prior opinion to clarify that a trial court must conduct a Marsden inquiry only when a defendant's request for substitute counsel directly or implicitly asserts inadequate performance by appointed counsel. It concluded that the defendant's requests, made amid repeated misconduct and disruptions, did not communicate a genuine complaint about counsel's performance, so the modification did not affect the judgment and rehearing was denied.