People v. Echavarria

In People v. Echavarria, 233 Mich App 356, 368; 592 NW2d 737 (1999), the Court set forth the following factors to be considered in determining whether the trial court abused its discretion in denying defense counsel's motion to withdraw and for a continuance to allow defendant to obtain new counsel: (1) whether the defendant is asserting a constitutional right; (2) whether the defendant has a legitimate reason for asserting the right, such as a bona fide dispute with his attorney; (3) whether the defendant was negligent in asserting his right; (4) whether the defendant is merely attempting to delay trial; (5) whether the defendant demonstrated prejudice resulting from the trial court's decision. Id. at 369.