Whitfield v. State
Appellate public defender sought to withdraw based on a claimed 'conflict of interest' arising from the defendant's pro se trial-court motion alleging his trial counsel (from the same PD office) misled him about his plea. The First DCA denied the motion, holding that section 27.5303(1)(a) only applies when a PD office represents two or more defendants with adverse interests, not when a single client alleges ineffective assistance against his own PD trial attorney. The court also found counsel failed to show the alleged conflict should be imputed to the entire office under Rule 4-1.10.
Key facts
- Defendant Whitfield, represented by the Public Defender office, filed a pro se motion in trial court alleging his trial counsel (also from the PD office) misled him about his plea.
- After conviction, appellate counsel from the same PD office sought to withdraw, claiming a conflict of interest based on the defendant's allegations against trial counsel.
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Why it matters
This opinion gives trial and appellate practitioners, especially assistant public defenders, clear guidance on the limited scope of section 27.5303(1)(a) and clarifies that a client's bare allegation of trial counsel's… — full analysis with a trial
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