State v. Lovell

In State v. Lovell, 1999 UT 40, 984 P.2d 382 (Utah 1999), the Supreme Court of Utah recognized the rule that when a defendant expresses dissatisfaction with counsel, the trial court must make reasonable efforts to determine the nature of the defendant's complaint. That court noted that it is not reversible error to fail to inquire when the complaints "do not rise to a constitutional level requiring the appointment of new counsel." 984 P.2d at 389. In Lovell, the court concluded the failure to inquire was harmless error because there was nothing to suggest that the outcome would have been different if different counsel had been appointed.