Montana Supreme Court

State v. J. Patina

November 6, 2024418 Mont. 523

Summary

The Montana Supreme Court affirmed the district court’s denial of a request to substitute counsel, holding that the trial court did not abuse its discretion because it conducted an adequate initial inquiry and found the defendant’s complaints were not "seemingly substantial" under established standards. The Court reiterated that substitution of counsel is limited to cases of actual conflict, irreconcilable conflict, or a complete breakdown in communication.