A defense lawyer’s request to be removed as counsel to a murder defendant was properly denied by the trial court—even though the defendant himself had requested new counsel—because “no conflict existed other than that created by defendant through his unjustified hostility toward his competent attorney,” a state appeals court has ruled.

An Appellate Division, First Department panel decided Tuesday that the defendant’s trial lawyer—unnamed in the opinion—had not presented a sufficient reason for removal when the lawyer joined defendant George Ventura’s application for new counsel and “cited only defendant’s recent request [for new counsel] and defendant’s belligerence in court the preceding day as the basis for his request.”