In State v. Maisonet, the New Jersey Supreme Court considered whether the defendant was denied his constitutional right to counsel when, on the day his murder trial was set to begin, he sought an adjournment to see if he could hire a private attorney, and his request was denied. When he requested the adjournment, the defendant stated that he could not go to trial with appointed counsel because she had tried only two cases in her career, neither of which were murder trials. The trial court denied the request, and a jury convicted the defendant of murder. The Court affirmed the conviction, holding that the defendant did not suffer an actual deprivation of the right to counsel of choice. The Court reaffirmed that, in considering a request for an adjournment, courts must use the eight factors outlined in United States v. Burton, 584 F.2d 485, 490-91 (D.C. Cir. 1978).
