Colorado v. Brown
Annotate this CaseThe issue for the Supreme Court's consideration in this case was the balance between a defendant's Sixth Amendment constitutional right to counsel of his or her choice and the public's interest in the fairness and efficiency of the judicial system. The Court of appeals developed a balancing test for a trial court to use when deciding whether to grant or deny a defendant's request for a continuance so that s/he may change counsel. The appellate court applied its test to the facts of this case and determined that the trial court abused its discretion and violated the defendant's constitutional rights to counsel of choice when it denied a request for a continuance. As a result, the appellate court reversed defendant's conviction and remanded the case for a new trial. The State appealed that outcome. While the Supreme Court agreed with the Court of Appeals that the decision whether to grant a continuance is a fact-based question best decided by the trial court, it declined to adopt the appellate court's test because it did not adequately reflect longstanding precedent requiring consideration of the "totality of the circumstances" when deciding on whether to grant a continuance. The Court concluded that the trial court record in this case was inadequate to determine whether the trial court abused its discretion when it denied the continuance. Accordingly, the Court reversed the appellate court's decision and remanded the case back to the trial court for additional findings and conclusions.
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