State v. Manross

The sole issue presented in this consolidated action is the determination of the appropriate standard for review of criminal convictions where the record shows that the trial court failed to inquire of co-defendants whether they wished to have separate counsel and where a potential conflict of interest arguably existed by reason of their joint representation by a single attorney.

Our analysis of the issues raised in this case must necessarily follow a two-tier approach. First, we determine whether the trial court must, as a matter of course, inquire of co-defendants whether they wish to have…