Holding: When evaluating motions to substitute counsel in capital cases under 18 U. S. C. § 3599, courts should employ the same “interests of justice” standard that applies in non-capital cases under 18 U.S.C. § 3006A. In this case, the district court did no abuse its discretion when, using the “interests of justice” standard, it denied Clair’s second request for new counsel. The Ninth Circuit erred in overturning that denial.
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