State v. King, 2018, UT App 190 (Oct. 4, 2018)
Vacating a $400 restitution order, the court of appeals held defendant was deprived of effective assistance of counsel, because counsel failed to object to a restitution request after filing a notice of withdrawal. In doing so, the court noted that proper withdrawal in a criminal case requires approval of the court. See Utah R. Crim. P. 36.