Legal Opinion

State v. Santacruz-Hernandez

Court of Appeals of Washington

Decided November 26, 2001No. 43926-0-IPublishedCited by 1 opinion

1Opinion of the CourtGrosse, J.

— When faced with a potential conflict of interest on the part of defense counsel, the trial court must make an inquiry into the nature of the conflict. The failure to do so is reversible error. Here, while the trial court did inquire, its failure to grant a short continuance to allow defense counsel to adequately address the potential conflict rendered that inquiry inadequate. Thus, we are constrained to reverse.

FACTS

Silviano Santacruz-Hernandez was charged in Skagit County with one count of intent to deliver cocaine and one count of unlawful intent to deliver heroin. The charges arose from…

2Cases cited5 opinions

  1. Cuyler v. SullivanSupreme Court of the United States · 1980
  2. Holloway v. ArkansasSupreme Court of the United States · 1978
  3. Wood v. GeorgiaSupreme Court of the United States · 1981
  4. In Re the Personal Restraint of RichardsonWashington Supreme Court · 1983
  5. In re the Disciplinary Proceeding Against McMurrayWashington Supreme Court · 1983

3Cited by1 opinion

  1. State v. Santacruz-HernandezCourt of Appeals of Washington · 2001

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