In People v Kieser, 79 N.Y.2d 936 (1992) the defendant was represented by an attorney licensed in New Jersey but who had been suspended for nonpayment of bar dues and had not been formally admitted to New York pro hac vice. The Court found that these minor deficiencies were not, in and of themselves, under the circumstances of the case, sufficient to constitute a violation of defendant's right to counsel. During the discussion of the legal issues, the Court of Appeals observed: "Thus, courts have distinguished between those defects that are 'technical,' i.e., those resulting from administrative suspension or censure for failure to comply with State Bar rules which have no bearing on the 'qualification, competence or moral character of the defendant's representative' . . . and those that are 'serious and substantive.' " (79 N.Y.2d at 937.) The Court held that: "Under the circumstances of this case, the failure of defendant's counsel, who at the time of defendant's trial was an attorney in good standing and duly licensed to practice law in New Jersey, to secure admission pro hac vice to practice in New York, did not affect his professional qualifications or competence such as to deprive defendant of his right to counsel under the Federal and New York State Constitutions. Nor did counsel's temporary suspension to practice law in New Jersey for nonpayment of Bar dues at the time he represented defendant deprive defendant of his right to counsel" (Kieser, 79 N.Y.2d at 937). In support of its holding, this Court found that the attorney's deficiencies were "technical" defects (defects that do not rise to the level of a violation of a defendant's right to counsel) (id.). Prior to making this finding, the Kieser Court distinguished "technical" defects from "serious and substantive" defects (those defects that rise to the level of a violation of a defendant's right to counsel) (id.). The Court stated that: "Although the defendant's right to counsel is guaranteed by the Sixth Amendment of the Federal Constitution and article I, 6 of the New York Constitution (US Const 6th, 14th Amends; NY Const, art I, 6), not every defect in an individual's ability to practice law renders his representation a deprivation of that right. Thus, courts have distinguished between those defects that are 'technical', i.e., those resulting from administrative suspension or censure for failure to comply with State Bar rules which have no bearing on the 'qualification, competence or moral character of the defendant's representative' and those that are 'serious and substantive' such as a representative's inability to practice law in any State because of a failure to seek admission or where admission to practice has been denied ' "for a reason going to legal ability, such as failure to pass a bar examination, or want of moral character" ' " (Kieser, 79 N.Y.2d at 937-938).