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P. v. Leal CA3
Defendant Stanley John Leal pleaded no contest to felony vandalism. (Pen. Code, § 594, subd. (b)(1).) The trial court sentenced him to a two-year state prison term.
Defendant now contends the trial court violated his state constitutional right to counsel by removing his appointed counsel without providing him notice or an opportunity to be heard. We conclude that although the substitution of counsel violated Code of Civil Procedure section 284, the error was harmless and did not violate the state constitutional right to counsel. We will affirm the judgment.

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