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Name: U.S. v. Adelzo-Gonzalez
Case #: 99-50152
Court: US Court of Appeals
District 9 Cir
Opinion Date: 09/26/2001
Subsequent History: None

Appellant made three written motions to substitute his attorney. The court did not make the letters part of the record and asked only open-ended questions about why counsel was not providing competent representation. There was a clear display of antagonism between counsel and client: appellant repeatedly said that they were not getting along, and defense counsel tried to prevent him from bringing the motions. Despite obvious signs of a serious conflict, the district court made no meaningful attempt to probe more deeply into the conflict. The Court of Appeals here reversed. The district court did not make an adequate inquiry and failed to recognize the material breakdown in trust and communication between appellant and his court appointed counsel. Therefore, the court abused its discretion in denying appellant’s motions and requiring him to continue with his representation as he pleaded guilty.