State v. Flores

I disagree with the majority's conclusion that appellate counsel need not obtain court approval to terminate representation of a *283client prior to filing a postconviction motion, notice of appeal or no merit report. I conclude that Flores received ineffective assistance of appellate counsel when counsel terminated her representation of Flores without the approval of the court. Thus, I would reverse the judgment outright and reinstate Flores' right to pursue his postconviction relief.

The majority correctly begins its analysis by observing that the Notice of Intent to Pursue Postconviction Relief…