Jesus Manuel Ronquillo v. the People of the State of Colorado

Summary

The court held that a criminal defendant may discharge retained counsel without showing good cause, even when seeking appointment of replacement counsel. Before permitting discharge, however, the trial court must determine how the defendant wishes to proceed, assess eligibility and scheduling consequences, and ensure that the defendant understands any resulting limitations. The court reversed the court of appeals and remanded because the lower courts applied the wrong legal standard and failed to conduct the required analysis.