Earl v. State
Annotate this CaseAppellant Cornelius Earl was convicted on three counts of delivery of a controlled substance and was sentenced to a total of 960 months' imprisonment. The court of appeals affirmed his convictions and sentence. Earl subsequently filed a petition for postconviction relief, alleging that his trial counsel operated under an actual conflict of interest due to counsel's simultaneous representation of Earl and his girlfriend, who also faced charges stemming from the same incident. Earl alternatively asserted that any waiver by him of the conflict was not knowing, voluntary, or intelligent. The circuit court denied the petition. Earl appealed, arguing that the trial court did not meaningfully inquire into the propriety of multiple representation. The Supreme Court affirmed, holding that because nothing in the circumstances of this case indicated that the trial court had a duty to inquire whether there was a conflict of interest, the inquiry was not insufficient, and therefore, the circuit court did not err in denying postconviction relief.
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