\u3cem\u3eState v. Cheetham\u3c/em\u3e: Montana Supreme Court Refuses to Substitute \u3cem\u3eStrickland\u3c/em\u3e Standard When Analyzing Substitution of Counsel Claims

Distinct from a criminal defendant’s right to effective assistance of counsel is a defendant’s right to counsel of choice. In State v. Cheetham, the Montana Supreme Court erroneously analyzed the defendant’s substitution of counsel claim under a standard that blends substitution of counsel with ineffective assistance of counsel