On Monday, the Supreme Court announced its decision in Martel v. Clair (No. 10-1265), in which it addressed the standard for replacement of appointed counsel under §3599 of Title 18. That statute entitles indigent defendants to the appointment of counsel in capital cases, including habeas corpus proceedings. While the statute provides that appointed counsel may be replaced upon motion of the defendant, it does not specify the standard that district courts should use in evaluating those motions. In an unanimous opinion delivered by Justice Kagan, the Court held "that courts should employ the same 'interests of justice' standard that they apply in non-capital cases under a related statute, §3006A of Title 18 . . . [and] that the District Court here did not abuse its discretion in denying respondent Kenneth Clair’s motion to change counsel."