The People of the State of Colorado v. Eric Lamont Brown

Summary

The court held that a trial court deciding whether to continue a trial so a defendant can retain counsel of choice must balance the defendant’s Sixth Amendment interest against the public’s interests in judicial efficiency and integrity, considering the totality of the circumstances. Because the record did not show that the trial court considered several relevant factors or made adequate findings, the court reversed the court of appeals and remanded for additional findings and conclusions rather than ordering a new trial. Justice Márquez, joined by Justices Coats and Eid, dissented, arguing that the majority’s required factor-by-factor record was an impermissibly mechanical test and that the existing record supported a new trial.