Hall v. Idaho
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Petitioner Erick Hall was convicted and sentenced to death twice: first for kidnapping, murder and rape; second for rape and murder. While Hall's petition for post-conviction relief was pending for his first sentence, his second trial for rape and murder was underway. During the overlap of Hall I and Hall II, there were numerous communications between Hall's trial attorneys representing him in Hall II, and the State Appellate Public Defender's (SAPD) office, handling Hall's post-conviction proceedings in Hall I. It was the communications between Hall's trial counsel that were the basis for a potential conflict of interest in this case, given that the issue before the Supreme Court in this appeal was ineffective assistance of trial counsel in his second petition for post-conviction relief. In 2008, Hall filed a petition for post-conviction relief in connection with his Hall II conviction. Two years later, the SAPD filed an Ex Parte Notice of Possible Conflict of Interest with the district court. The Ex Parte Notice stated that the SAPD had "cooperated with trial counsel in Hall II by sharing testing and expert information obtained in Hall I." Dennis Benjamin [. . .] agreed to evaluate the conflict and advise Mr. Hall whether or not the conflict should be waived." With no knowledge of the Ex Parte Notice, the State filed a Motion for Inquiry into Possible SAPD Conflict. Although Benjamin conducted an extensive inquiry into whether the SAPD was conflicted, the district court did not question Benjamin about his findings. Rather, the court believed that Benjamin was too closely aligned with the SAPD to be truly independent. The court then issued a Memorandum Decision and Order Appointing Keith Roark as Independent Counsel. The SAPD filed a Motion to Reconsider Memorandum Decision, which the court denied. On appeal, Hall acknowledged the trial court had an affirmative duty to inquire into a potential conflict whenever it knew or reasonably should have known that a particular conflict may exist. However, Hall argued that the cases relied on by the district court in finding that it had an affirmative duty to conduct a thorough and searching inquiry were distinguishable because the possibility of a conflict in this case was raised by Hall's counsel, not Hall himself. Additionally, Hall contended that Roark's conflict inquiry was unnecessary and duplicative because: (1) Benjamin assessed the possible conflict and concluded no conflict existed; and, (2) Benjamin made his conclusion after reviewing all relevant information. Further, Hall argued that the district court's second inquiry was unnecessary because the conduct of Hall's previous attorneys at the SAPD's office should not have been imputed to Hall's then-current post-conviction counsel. After its review, the Supreme Court concluded the district court erred in appointing Roark as independent counsel; the district court order granting Roark access to the SAPD's client file violated Hall's attorney-client privilege. Therefore the Supreme Court vacated the district court's order appointing Roark as independent conflict counsel and its order requiring the SAPD to pay for Roark's services.
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