Assistance of Counsel Requires Bar Membership

In In re Johnson (1992) 1 Cal.4th 689, 694, the Supreme Court held that “representation by an attorney who has submitted a resignation with disciplinary proceedings pending, and has as a result been placed on inactive status, denies a criminal defendant the counsel guaranteed by article I, section 15 of the California Constitution.” Moreover, the error is reversible per se. Id. at 701. But what if a criminal defendant's lawyer loses his license in the middle of a trial? That's what happened in People v. Vigil (here) and the Court of Appeal held that the defendant was entitled to a new trial, even if the defrocked lawyer did a good job in the last day of a four-day trial.