UNITED STATES OF AMERICA v. CHRISTEN L. CLARK
The Sixth Circuit vacated the district court's denial of a defendant's motion to withdraw a guilty plea, ruling that the sudden resignation of counsel due to pending disciplinary action created a presumption of ineffective assistance requiring an evidentiary hearing. The court held that the district court abused its discretion by relying solely on the plea colloquy without resolving factual disputes regarding the voluntariness of the plea.