Mathis v. State
On remand for a Sheppard hearing on Mathis's pro se motion to withdraw his plea based on alleged coercion and misadvice by counsel, the trial court took testimony from both Mathis and his attorney, resolved the credibility dispute against Mathis, and denied the motion without ever appointing conflict-free counsel. The Fifth DCA reversed, holding that once the court had counsel testify against her own client's factual allegations, an adversarial relationship arose requiring appointment of conflict-free counsel before the merits hearing.
Key facts
- Mathis filed a pro se motion to withdraw his guilty plea, alleging his trial counsel coerced him and provided misadvice.
- At the Sheppard hearing, the trial court heard testimony from both Mathis and his counsel, who contradicted Mathis's allegations, and then denied the motion without appointing conflict-free counsel.
- +2 more key facts with a free trial
Why it matters
This decision gives criminal practitioners a concrete application of Sheppard's conflict-free-counsel requirement, clarifying that a trial court cannot conduct a combined hearing where counsel testifies adversarially to… — full analysis with a trial
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