State of New Jersey, Plaintiff-Appellant v. Raymond D. Kates, Defendant-Respondent

Summary

The Supreme Court of New Jersey affirmed the Appellate Division’s order for a new trial, holding that a trial court’s summary denial of a continuance to retain counsel of choice without analyzing the governing factors violates the defendant’s Sixth Amendment right and constitutes structural error. The Court also reiterated that an indigent defendant represented by appointed counsel does not have a constitutional right to choose counsel.