4.7Substitution or Withdrawal of Attorney

A.Order Required

“Unless otherwise stated in [MCR 2.117], an attorney who has entered an appearance may withdraw from the action or be substituted for only on order of the court.” MCR 2.117(C)(2). See also Coble v Green, 271 Mich App 382, 386-387 (2006).

“An attorney who has filed a notice of limited appearance^[1] pursuant to MCR 2.117(B)(2)(c) and MRPC 1.2(b) may withdraw by filing a notice of withdrawal from limited appearance with the court, served on all parties of record, stating that the attorney’s limited representation has concluded and the attorney has taken all actions necessitated by the limited representation, and providing to the court a current service address and telephone number for the self-represented litigant.” MCR 2.117(C)(4). The notice of withdrawal from limited appearance is effective immediately upon filing and service if it is signed by the client; it is effective 14 days after filing and service if it is not signed by the client, “unless the self-represented client files and serves a written objection to the withdrawal on the grounds that the attorney did not complete the agreed upon services.” Id.

Where the court has ordered an attorney to continue representing a client, the attorney must continue with the representation even if good cause exists for terminating the representation. MRPC 1.16(c).

B.Standard of Review

A trial court’s decision regarding a motion to withdraw is reviewed for an abuse of discretion. In re Withdrawal of Attorney, 234 Mich App 421, 431 (1999).