Snow v. State, 270 P.3d 656

Snow was convicted of burglary and a related misdemeanor in Wyoming.
He challenged the denial of substitute counsel and alleged ineffective assistance of counsel.
A status hearing addressed Snow's request for substitute counsel and his right to counsel or to proceed pro se.
Snow indicated he did not want to retain a different lawyer and wished to proceed with appointed counsel.
The district court advised Snow of his rights, including waiving counsel or obtaining new counsel, and Snow declined.
On appeal, the court affirmed, holding the district court did not abuse its discretion and defense counsel was not ineffective by not offering a lesser-included offense instruction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court failed to properly inquire about substitute counsel and pro se option.	Snow.	Snow contends inquiry was inadequate.	No abuse of discretion; court properly addressed request.
Whether trial counsel was ineffective for not requesting a lesser-included offense instruction.	Snow.	Snow failed to prove entitlement to such instruction.	Not ineffective; strategy supported by record; elements disputed or not conducive.

Allen v. State, 48 P.3d 551 (Wyoming 2002) (review of substitute-counsel inquiry; right to counsel not absolute control by defendant)
Strickland v. State, 94 P.3d 1034 (Wyoming 2004) (ineffective-assistance standard; two-prong test; prejudice required)
Robison v. State, 246 P.3d 259 (Wyoming 2011) (standard for evaluating counsel performance in context)
Dean v. State, 77 P.3d 692 (Wyoming 2003) (five-part test for lesser-included offenses)
Eatherton v. State, 761 P.2d 91 (Wyoming 1988) (five-part framework for lesser-included offense instructions)
Collins v. State, 854 P.2d 688 (Wyoming 1993) (instruction proper only when elements support lesser offense)