State v. Glenn, 221 N.C.App. 143, 726 S.E.2d 185 (Jun. 5, 2012)

The trial court did not abuse its discretion by denying the defendant’s motion to replace his court-appointed lawyer. Substitute counsel is required and must be appointed when a defendant shows good cause, such as a conflict of interest or a complete breakdown in communications. However, general dissatisfaction or disagreement over trial tactics is not a sufficient basis to appoint new counsel. In this case, the defendant’s objections fell into the latter category. The court also rejected the defendant’s argument that the trial court failed to inquire adequately when the defendant raised the substitute counsel issue.