October 16, 2017
2017 CO 99. No. 14SC341. Ronquillo v. People.
Criminal Law—Counsel—Choice of Counsel—Continuance.
The Supreme Court held that the Sixth Amendment right to counsel of choice includes the right to fire retained counsel without having to show good cause, even when the defendant wants appointed counsel. But defendants who fire retained counsel will not necessarily be allowed to proceed as they wish. Accordingly, trial courts must ensure that defendants understand the consequences of firing retained counsel. The Court outlined the analysis that trial courts should conduct before releasing retained counsel from a case. Because the Court of Appeals erred by requiring Ronquillo to show good cause for firing retained counsel, the Court reversed and remanded for further proceedings.