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“However, the right of an indigent to have counsel does not give him the unbridled right to be represented by counsel of his choice.”

(“[T]he right of an indigent to have counsel does not give him the unbridled right to be represented by counsel of his choice.”).

District courts grant an indigent defendant’s request for different counsel “only if exceptional circumstances exist and the demand is timely and reasonably made.”

A district court’s decision to grant or deny a continuance “should be based on all facts and circumstances surrounding the request.”

(finding no abuse of discretion because the defendant was “provided with a competent and able public defender who had thoroughly investigated the facts and was prepared for trial); Worthy, d at 278 (concluding the [district] court did not abuse its discretion in the denial of a continuan

In evaluating a district court’s decision to deny a continuance, appellat e courts consider “whether the defendant was so prejudiced in preparing or presenting his defense as to materially affect the outcome of trial.” -59 (Minn. 1977).

13, 1991); (noting that an indigent defendant may request substitute counsel, but the “request will be granted only if exceptional circumstances exist and the demand is timely and reasonably made”).

The prejudice standard applicable to a due-process challenge to a district court’s decision to proceed by default requires the claimant to show that the decision prejudiced the “preparation or presentation of their case so as to ‘materially affect the outcome of the trial.’” G.A.H., d at 238 ().

See Ungar, 376 U.S. at 590–91 (observing that the party seeking the continuance had time to take steps to hire counsel, obtain needed evidence, and prepare for the hearing); –59 (Minn. 1977) (considering among other factors that the defendant waited until the eve of trial to substitute counsel); (considering among other factors that defendant could have located private counsel in the 3 months he was in custody prior to trial); T.D.F., 2

A defendant cannot demand a continuance for the purpose of delay or by “arbitrarily choosing to substitute counsel at the time of trial.” ().

-59 (Minn. 1977) (holding that there was no abuse of discretion when the defendant made a motion for a continuance a few days before trial where the public defender was competent).

In addition, the district court must base its decision “on all facts and circumstances surrounding the request.” State v. Vance

The constitutional right to assistance of counsel discussed in the previous section “includes a [defendant’s] fair opportunity to secure counsel of his choice.”

If an indigent defendant requests the substitution of a court-appointed attorney, a district court must grant the request “‘only if exceptional circumstances exist and the demand is timely and reasonably made.’” ().

13, 1991); see also State v. Vance , -59 (Minn. 1977) (noting that an i ndigent defendant may request substitute counsel, but the “request will be granted only if exceptional circumstances exist and the demand is timely and reasonably made”).

2052 , 80 L.Ed.2d 674 (1984) ; State v. Vance , , 358 (Minn. 1977).

This right permits a defendant “a fair opportunity to secure counsel of his choice.”

State v. Vance , 8 (Minn. 1977).

“This right includes a fair opportunity to secure counsel of [the defendant’s] choice.”

And a district court’s decision to grant or deny a continuance “should be based on all facts and circumstances surrounding the request.” d 353, 358 (Minn. 1977).

See, d 270, 278 (Minn. 1998) (holding no abuse of discretion by denying a continuance requested a few days before trial by defendant who did not have good cause to dismiss his court- appointed attorney); (affirming denial of continuance requested a few days before trial because public defender was competent); State v. Ahearn, 292 Minn. 449, 450, (affirming denial of continuance requested the day before trial because there was no substantial basis for dissatisfaction or

A request for substitution of counsel will be “granted only if exceptional circumstances exist and the demand is timely and reasonably made.”

(noting a defendant was not entitled to a continuance where “he had no cause to be dissatisfied with his assigned counsel”).

A criminal defendant’s right to counsel entitles the defendant to be allowed “a fair opportunity to secure counsel of his choice,” and an indigent defendant must “be provided competent counsel in all criminal proceedings.”

The decision “should be based on all facts and circumstances surrounding the request [for a continuance].”

Although he may request a substitution of counsel, his request will be granted only if exceptional circumstances exist and the 7 demand is timely and reasonably made.”

“This right includes a fair opportunity to secure counsel of his choice.” d 353, 358 (Minn. 1977).

2052 , 80 L.Ed.2d 674 (1984)

A defendant cannot demand a continuance for the purpose of delay or by “arbitrarily choosing to substitute counsel at the time of trial.”