People v. Bryan

Judgment, Supreme Court, New York County (Lewis Bart Stone, J), rendered March 15, 2005, convicting defendant, after a jury trial, of criminal sale of a controlled substance in the third degree and sentencing him, as a second felony offender, to a term of 4±k to 9 years, unanimously reversed, on the law, and the matter remanded for a new trial.

Defendant’s constitutional right to counsel was violated when the trial court denied his request for substitution of counsel without making any inquiry or giving defendant an opportunity to state the basis of his complaint, and instead, diverted…