Maricopa County Public Defender's Office v. Superior Court
In Maricopa County Public Defender's Office v. Superior Court, 187 Ariz. 162, 927 P.2d 822 (App. 1996), the Court held that that a trial court must determine whether a defendant's motion for substitute counsel is proper without "inquiry into the area of confidential communications."
That case, addressed an attorney's motion to withdraw from a case, not a defendant's motion for substitute counsel based, in part, on counsel's asserted representations. Id. at 164, 927 P.2d at 824.
There, the Court held a trial court must give "great weight" to an attorney's "avowal of an ethical conflict requiring withdrawal" because "'attorneys are officers of the court, and when they address the judge solemnly upon a matter before the court, their declarations are virtually made under oath.'" Id. at 166, 927 P.2d at 826.