In Re the Personal Restraint of Richardson

In this personal restraint petition, petitioner Gary Richardson raises several claims. While we conclude that most of them lack merit, his claim of ineffective assistance of counsel is meritorious. The record establishes that trial counsel previously represented an important witness in the case. This establishes a prima facie case of ineffective assistance of counsel, for the trial court should have been aware of and inquired into this potential conflict of interest. If a potential conflict of interest existed, the trial court's failure to inquire automatically requires reversal even without…