People v. Bowman

We reject defendant’s contention that the trial court deprived him of the right to. retain counsel of his own choosing by failing to conduct a minimal inquiry into the merits of the allegations set forth in his pro se motion for assignment of substitute counsel. Although engaging in a brief and direct inquiry into the reasons for defendant’s dissatisfaction with counsel would likely have obviated this appeal, Justice Berkman’s failure to do so does not warrant reversal. There were no specific factual allegations in defendant’s pro se motion that would indicate a serious conflict with counsel…