Alvaro Noe Mendoza-Valencia v. Oregon
1. Can a state trial court deny a criminal defendant's request for substitution counsel without any reasonable inquiry into trial counsel's performance, and then proceed with a jury trial without the defendant being present?
2. In denying a pretrial motion for substitution counsel, should a trial court be required to make reasoned findings of fact on the record to ascertain effective assistance of counsel under the Sixth Amendment to the United States Constitution?
3. When the Attorney-Client Relationship completely breaks down to the point where a criminal defendant refuses to participate in the jury trial process, at what time and in what manner should the trial court take direct intervention to protect the integrity of the Sixth Amendment's guarantee of assistance of counsel?
Can a state trial court deny a criminal defendant's request for substitution counsel without any reasonable inquiry into trial counsel's performance, and then proceed with a jury trial without the defendant being present?