The People of the State of Colorado, Petitioner v. April Rose Travis, Respondent.

Summary

The court held that a defendant’s bare request on the day of trial for more time to “look for and pay for an attorney” does not invoke the Sixth Amendment right to counsel of choice because no replacement lawyer had been identified or retained. The trial court therefore was not required to make specific findings under the eleven-factor continuance analysis, and its denial of the continuance was not an abuse of discretion. The court reversed the court of appeals and remanded for proceedings consistent with its opinion.