People v. Windham

In People v. Windham (1977) 19 Cal.3d 121, the Supreme Court directed trial courts to consider the "quality of counsel's representation of the defendant, the defendant's prior proclivity to substitute counsel, the reasons for the request, the length and stage of the proceedings, and the disruption or delay which might reasonably be expected to follow the granting of such a motion." ( Id. at p. 128.)