Yes, if the court conducts a thorough analysis of the factors listed in United States v. Burton and those factors favor denial of Defendant’s request.
In March of this year the New Jersey Supreme Court dealt with this very issue in the context of a murder trial. In State v. Luis Maisonet, the Defendant’s request for a new attorney was summarily denied by the trial court. The record presented a dearth of facts regarding the Burton factors. Nonetheless, the New Jersey Supreme Court found that it could glean sufficient information from the record to analyze the Burton factors in a fashion that militated against the Defendant.
Before conducting its analysis the Court explained that the major considerations any trial court should contemplate are those of the Defendant’s constitutional right to obtain counsel of his choice, the court’s right to control its own calendar and the public’s interest in the orderly administration of justice.