State v. Johnson
In its 1993 decision in State v. Robinson, the Connecticut Supreme Court explained that "[w]here a defendant voices a seemingly substantial complaint about counsel, the court should inquire into the reasons for dissatisfaction…" Following a jury trial, Nathan Johnson was convicted of carrying a pistol without a permit, interfering with an officer and criminal possession of a firearm. He appealed claiming that he was entitled to a new trial because the court violated his state and federal right to counsel of his choice and abused its discretion in failing to conduct an inquiry when it learned that the defendant no longer wanted to be represented by his private attorney. The Appellate Court affirmed the judgment. Prior to jury selection the court addressed the defendant noting that counsel mentioned that the defendant might want to address the court and asking if that was the case or were they "set to go." The defendant stated that they were "set to go." Counsel addressed the court and asked to put on the record that there were some indications from the defendant "that he did not want me as his attorney." The Appellate Court concluded that the trial court did not violate the defendant's right to counsel of choice, nor did it abuse its discretion when it did not address further counsel's statement for the record. The court timely gave the defendant and his attorney an opportunity to confer during the hearing and the defendant, thereafter, stated that he was ready to proceed. Any inquiry by the court at that juncture was unnecessary and could have intruded into the attorney-client relationship. There being no indication from the defendant that there was an ongoing substantial disagreement, the court properly continued with the hearing, not interfering with the attorney-client relationship.