In the Matter of the Personal Restraint of: Robert L. Ayerst

FILED MAY 4, 2021 In the Office of the Clerk of Court WA State Court of Appeals, Division III IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE In the Matter of the Personal Restraint of: ) No. 36965-0-III ) ROBERT L. AYERST, ) OPINION PUBLISHED IN PART ) Petitioner. ) PENNELL, C.J. — The federal and state constitutions entitle the criminally accused to representation by counsel before an impartial tribunal. These protections are undermined when trial counsel or the judge is engaged in criminal activity. A defendant seeking to overturn a conviction based on criminal activity…