State v. Covington, 205 N.C.App. 254, 696 S.E.2d 183 (Jul. 6, 2010)

The trial court did not abuse its discretion by denying the defendant’s request for substitute counsel where there was no evidence that the defendant’s constitutional right to counsel was violated. The defendant waived the right to appointed counsel and retained an attorney. The day after the jury was impaneled for trial the defendant requested substitute counsel, asserting that counsel had not communicated enough with him, that the defendant was unaware the case would be tried that day, and that he had concerns about counsel’s strategy, particularly counsel’s advice that the defendant not testify. None of these concerns constituted a violation of the defendant’s constitutional right to counsel.