People v. Alengi

Introduction

We granted certiorari to resolve a split of authority between two divisions of the court of appeals, which adopted different analyses and reached opposite results in identical appeals. Nancy and Paul Alengi, a married couple, were tried and convicted in a joint trial of the same offenses. Prior to trial, the Alengis’ privately-retained attorneys were allowed to withdraw from representation. Thereafter, the Alengis repeatedly advised the court they were in the process of converting their assets to cash in order to retain replacement counsel. The court gave the couple an Arguello…