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.
Cori Losing, Case Note, State v. Cheetham: Montana Supreme Court Refuses to Substitute Strickland Standard When Analyzing Substitution of Counsel Claims, 77 Mont. L. Rev. Online 143, https://scholarship.law.umt.edu/mlr_online/vol77/iss1/19.