the Tenth Circuit upheld the district court’s determination that an interpreter was not required for the defendant, a Mexican natural, who occasionally spoke English, spoke English with his lawyer and during the court proceedings, and who had never requested an interpreter. Though not all states have the equivalent of the Act to guide their courts with decisions regarding the appointment of an interpreter, similar principles can be discerned from case law. For example, other states’ laws similarly provide that a court’s obligation to provide a non-English speaking defendant with an interpreter is not triggered absent a request by a defendant or some obvious manifestation of a significant language difficulty. See, e.g., People v. Atsilis, 60 Mich.App. 738, 231 N.W.2d 534, 535 (1975) (<HOLDING>); State v. Woo Won Choi, 55 Wash.App. 895, 781
holding that where no factual dispute is raised no hearing is required holding where there is no duty to defend there is no duty to indemnify holding that a trial judge is under no duty to affirmatively establish a defendants proficiency in english where no evidence on the issue is presented holding that if no evidence was presented to support the prevailing party there is no evidence upon which to apply the substantial evidence test and therefore the capricious disregard standard applies holding that trial court has no duty to establish waiver on record