The Sixth Circuit has affirmed the denial of a motion to continue by a pro se litigant when his attorney advised him 6 weeks prior to the merits hearing that if he did not pay the balance owed, his attorney would withdraw; the attorney moved to withdraw one week prior to the merits; and the judge granted the motion to withdraw on the day of the merits. Thought the court dismissed the petition for review, it noted that, “[w]e do not hereby endorse the practices employed by either the withdrawing attorney or the IJ. “

The full text of Mendoza-Garcia v. Barr can be found here: