Gerald Claude Carlson v. United States

Whether the Carlson Court’s Memorandum Opinion conflicts with other Ninth Circuit opinions holding that a finding of substantial or undue delay is required to deny a criminal defendant’s motion to terminate his retained counsel pursuant to his Sixth Amendment right to counsel of his choice and that the extent of conflict inquiry is inapt in such circumstances?

Whether this Court should exercise its supervisory powers where the Carlson Court conceded that the District Court’s “description of its reasons for denying the request [to terminate retained counsel] may not have been stated in the clearest and most comprehensive of manner, it is apparent here that the denial was primarily based on the demands of its calendar” and where the District Court cited only to the vaguest notions of efficiency and neither court made a finding of substantial or undue delay?

Whether the Carlson Court’s Memorandum Opinion conflicts with other Ninth Circuit cases holding that a court must balance a criminal defendant’s Sixth Amendment right to counsel of choice with the delay and inconvenience resulting from the substitution of counsel?

Whether this Court should resolve an apparent internal Circuit split regarding the proper standard for a motion to terminate retained counsel?