State v. Vaughan
Annotate this CaseAfter a jury trial, Defendant was found guilty of first-degree arson. On appeal, Defendant requested a judgment of acquittal or, alternatively, a new trial, claiming that the evidence was insufficient to support the conviction and that his pretrial counsel operated under a conflict of interest due to his representation of a prosecution witness. The court of appeals reversed, holding that Defendant’s pretrial counsel’s conflict of interest required reversal of Defendant’s conviction. The Supreme Court vacated the decision of the court of appeals and affirmed the district court’s judgment of conviction and sentence, holding that, where the district court replaced the conflicted defense attorney with a conflict-free attorney more than three months before trial, and there was no showing that the previous conflict had ongoing adverse effects on the representation, a new trial was not required.
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