A defendant who was refused assigned counsel on the eve of trial after his retained counsel had already expended substantial efforts on his behalf has no claim that the trial court violated his Sixth Amendment rights, the 2nd U.S. Circuit Court of Appeals has ruled.

Rejecting the claim of former Buffalo Police Detective Darnyl Parker, the circuit also turned back a challenge to the Western District’s practice of seeking assurance that counsel has been “fully retained” for the duration of the proceedings as a prerequisite to counsel’s approved appearance for the accused.