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¶23 The Sixth Amendment gives a criminal defendant a right to counsel, but a defendant is not “entitled to counsel of choice or to a meaningful relationship with his or her attorney.” ¶ 28 (2005).

¶15 “A trial court’s decision to deny the request for new counsel will not be disturbed absent an abuse of discretion.” ¶ 27 (2005).

(concluding that defendant’s sentence was properly enhanced “on 4 STATE v. JERALD Opinion of the Court express findings by the jury that the victim was a child under twelve years of age and that [the defen

¶8 “A trial court’s decision to deny the request for new counsel will not be disturbed absent an abuse of discretion.” ¶ 27 (2005).

ial so that he could do so, he did not provide specific allegations about why he wanted new counsel, asserting only that his counsel was not “fighting hard enough.” In the criminal context, “[a] single allegation of lost confidence in counsel does not require the appointment of new counsel, and disagreements over defense strategies do not constitute an irreconcilable conflict.” ¶ 29 (2005); see Morris v. Slappy, 461 U.S. 1, 14 (1983) (right to counsel does not guarantee a “meaningful relationshi

at 343, ¶ 9; ¶ 29 (2005) ("The presence of an irreconcilable conflict or a completely fractured relationship between counsel and the accused ordinarily requires the appointment of new counsel.").

9 ¶ 29 (2005) (“A single allegation of lost confidence in counsel does not require the appointment of new counsel .

A defendant must show more than “personality conflicts or disagreements with counsel over trial strategy.” ¶ 30 (2005).

-88 ¶¶ 19-37 (2005) (affirming denial of defendant’s request for new counsel); ¶ 8 (2004) (holding that court must grant a request for new counsel where a defendant establishes an “irreconcilable conflict with his attorney”).

¶9 A superior court ruling regarding a request for substitute counsel “will not be disturbed absent an abuse of discretion.” ¶ 27 (2005).

It is “constitutionally impermissible” to require a party entitled to counsel to choose between self-representation and “representation by a lawyer with whom [s]he had a completely fractured relationship, clearly an ‘irreconcilable conflict.’” Moody, , 968 P.2d at 582 ; , (“irreconcilable conflict” or “completely fractured” attorney-client relationship “ordinarily requires the appointment of new counsel”).

See Torres, 208 Ariz. at 343 ¶ 8, 93 P.3d at 1059 (“[G]eneralized complaints about differences in strategy may not require a formal hearing or an evidentiary proceeding.”); ¶ 30, (“To constitute a colorable claim, a defendant’s allegations must go beyond personality conflicts or disagreements with counsel over trial strategy.”).