The Court determined that (1) when the government relies on the forfeiture exception of the Confrontation Clause to introduce a witness’s out-of-court statements, the burden of proof the litigant must meet is that of preponderance of the evidence; and (2) that a trial court does not abuse its discretion in denying a motion to substitute counsel and thereby violate the Sixth Amendment right to counsel when the trial court holds a Young hearing for each motion and enough evidence indicates there is not a complete breakdown in the attorney-client relationship.
Bingham, Tayler, "Anderson v. State, 135 Nev. Adv. Op. 56 (Nov. 27, 2019)" (2020). Nevada Supreme Court Summaries. 1283.