United States v. Marcos Siordia-Felix

97 F.3d 1463 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. UNITED STATES of America, Plaintiff-Appellee, v. Marcos SIORDIA-FELIX, Defendant-Appellant. No. 93-50720. United States Court of Appeals, Ninth Circuit. Argued and Submitted March 8, 1996. Decided Sept. 26, 1996. Before: BROWNING, WALLACE, and FARRIS, Circuit Judges. 1 MEMORANDUM * 2 A criminal defendant has a Sixth Amendment right to retain counsel of his choice. See Wheat v. United States, 486 U.S. 153, 159 (1988). "Absent ... a compelling purpose, ... it is a violation of the Sixth Amendment to deny a motion to substitute counsel and an error that must be reversed, regardless of whether prejudice results." United States v. D'Amore, 56 F.3d 1202, 1204 (9th Cir.1995). A compelling purpose may exist "when granting the motion would lead to a delay in the proceedings and the Government's interest in the prompt and efficient administration of justice outweighs the defendant's need for new counsel to adequately…