People v. Brown

Opinion by

Judge WEBB.

This direct appeal presents the difficult question of balancing efficient judicial administration against delay when a criminal defendant exercises his Sixth Amendment right to replace appointed counsel with retained counsel and seeks to continue the trial on that basis. Although denying a continuance is within the trial court's discretion, here the court's findings do not show that it adequately considered the right of defendant, Eric Lamont Brown, to counsel of his choosing when it refused to continue the trial to afford his newly-retained counsel time to prepare.…