MARIO THOMAS
v.
THE STATE OF FLORIDA
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A trial court does not abuse its discretion in denying a defendant's request for new private counsel when the request is made immediately before trial and appears motivated by delay.
[1] A trial court does not commit reversible error by denying a defendant's request for substitute counsel when made on the eve of trial and in apparent bad faith for purpose…
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Join FLexlaw to unlock all legal intelligenceMario Thomas appealed from multiple convictions in Miami-Dade County, challenging the trial court's denial of his request for substitute private couns…
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PER CURIAM.
Affirmed. See Lelieve v. State, 7 So. 3d 624, 629 (Fla. 3d DCA 2009)
(defendant not entitled to reversal where request for new private counsel was
denied on heels of denial of request for continuance made only for purpose
of delaying trial); Wade v. State, 30 So. 3d 640, 643 (Fla. 4th DCA 2010)
(concluding no “palpable abuse of judicial discretion” shown where defense
had three prior continuances and court was not alerted that defendant
wished to substitute his counsel until morning of trial); see also Hurtado v.
State, 760 So. 2d 279, 280 (Fla. 4th DCA 2000) (trial court did not abuse
discretion in denying request for new counsel on grounds that “[defendant’s]
request was made in bad faith and for the sake of arbitrary delay”).
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Hurtado v. State, 760 So. 2d 279 (Fla. 4th DCA 2000)
- Lelieve v. State, 7 So. 3d 624 (Fla. 3d DCA 2009)
- Cephus Wade v. State, 30 So. 3d 640 (Fla. 4th DCA 2010)