State v. Valencia

In State v. Valencia, 2001 UT App 159, 27 P.3d 573, 576 (Utah App. 2001), the Utah appeals court concluded that the trial court erred in not conducting a more meaningful inquiry into the defendant's complaints when it asked only a very few questions to "'explore the substantiality of Valencia's allegations.'" The appellate court determined that the error was harmless because the record contained enough information to support the trial court's finding that good cause to substitute counsel did not exist.