Court's Refusal to Appoint New Counsel (After Discharge) In Connecticut
The standard of reviewing both a motion by a defendant to discharge counsel and a motion by counsel to withdraw is the same. See State v. Patavino, 51 Conn. App. 604, 608-609, 724 A.2d 514, cert. denied, 249 Conn. 919, 733 A.2d 236 (1999).
It is within the trial court's discretion to determine whether a factual basis exists for appointing new counsel and, absent a factual record revealing an abuse of that discretion, the court's refusal to appoint new counsel is not improper. State v. Crenshaw, 210 Conn. 304, 314, 554 A.2d 1074 (1989).
Moreover, appellate tribunals "look with a jaundiced eye at complaints regarding adequacy of counsel made on the eve of trial . . . ." State v. Robinson, 227 Conn. 711, 726, 631 A.2d 288 (1993).
Such a request must be supported by a substantial reason and, "in order to work a delay by a last minute discharge of counsel there must exist exceptional circumstances." State v. Webb, 238 Conn. 389, 424, 680 A.2d 147 (1996).