The right to counsel of choice is measured against the trial court's interest in trying the case with diligence and the orderly process of judicial administration. People v. Brisco, 2012 IL App (1st) 101612, ¶ 41. "Therefore, the trial court may consider the defendant's reasons for seeking new counsel, whether the request is merely a guise to thwart effective prosecution, whether the defendant has cooperated with current counsel, and the length of time the defendant has been represented by current counsel." Id.
No attorney appeared ready, willing, and able to appear for defendant to begin trial. ¶ 75 Defendant argues that the trial court's requirement that a new attorney be ready for trial was unreasonable and an abuse of discretion. Defendant relies on People v. Brisco, 2012 IL App (1st) 101612, for support. In that case, a new attorney sought to substitute as counsel for posttrial proceedings, but requested additional time to supplement a previously filed motion for a new trial.
Rather, to show bias, a defendant must demonstrate "active personal animosity, hostility, ill will or distrust toward him" by the court. People v. Brisco, 2012 IL App (1st) 101612, ¶ 29, 971 N.E.2d 20.¶ 49 Our review of the record reveals defendant's allegations of judicial bias are without merit. For example, defendant alleges the trial court interrupted him and gave legal advice to the State.
Furthermore, in making its statements during closing argument, the court was merely inquiring about the unresolved question raised by the conflicting testimony and counsel's theory, which is the role of the trier of fact and not an example of bias. See People v. Brisco, 2012 IL App (1st) 101612, ¶ 30 (finding that the court's statements, when viewed in context, did not show bias but instead reflected the court's attempt to reconcile conflicting representations).