State v. Galaviz

The opinion of the court was delivered by

LüCKERT, J.:

In this appeal involving a probation revocation, Jose Galaviz argues his attorney’s position as the guardian ad litem for the victim of one of Galaviz’ crimes created a per se conflict of interest that denied Galaviz his right to effective assistance of counsel at his probation revocation proceeding. Galaviz, citing State v. Jenkins, 257 Kan. 1074, 898 P.2d 1121 (1995), argues this conflict so offended his rights as guaranteed by the Sixth Amendment to the United States Constitution that reversal is automatic and he is not required to show…