In United States v. Jimenez-Antunez, the United States Court of Appeals for the Eleventh Circuit held that a defendant is not required to show good cause to dismiss his retained counsel, even if the defendant then intends to request appointed counsel. The issue was one of first impression in the Eleventh Circuit, and one that has caused some disagreement between the other circuits. There are distinct differences between the right to appointed counsel and the right to retained counsel under the Sixth Amendment of the United States Constitution. This case continues to uphold those distinctions by keeping the standards to substitute counsel separate.
"Methamphetamine, Money, and a Motion to Withdraw as Counsel: United States v. Jimenez-Antunez All Boils Down to the Appropriate Standard-,"
Mercer Law Review: Vol. 68:
3, Article 14.
Available at: https://digitalcommons.law.mercer.edu/jour_mlr/vol68/iss3/14