State v. Bell

I concur in the result reached by the Court. I agree with the majority that “there is no presumed or per se rule of conflict of interest” regarding the representation of multiple defendants by staff attorneys at the same public defender’s office. Ante at 171.

The majority’s opinion has additional significance. In resolving the claims of ineffective assistance of counsel in this case, the Court uses a balancing approach. It holds that a conflict of interest with resulting prejudice to defendants will be presumed only when “the circumstances demonstrate a potential conflict of interest and a…