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A13-0388 State v. Parks (Benton County)

Right to Counsel – Substitute Counsel


Appellant challenged his convictions of first-degree burglary and misdemeanor domestic assault, arguing that the District Court (1) misstated the law or abused its discretion by denying appellant the appointment of substitute counsel and (2) abused its discretion by admitting evidence of his being under the influence of a controlled substance at the time of his arrest. Appellant argued that even if his complaint at the District Court’s pretrial hearing did not in itself justify the appointment of substitute counsel, the District Court was obligated to conduct a “searching inquiry” to determine whether such a justification existed. However, the Court of Appeals noted that appellant did not voice “serious allegations of inadequate representation.” He complained about his attorney’s attitude. Affirmed.

A13-0388 State v. Parks (Benton County)

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