Idaho v. Alvarado
Annotate this CaseIn this appeal, the Idaho Supreme Court was asked to clarify the meaning and extent of a defendant’s Sixth Amendment right to conflict-free counsel. Appellant Alfredo Alvarado argued his rights were violated because his public defender had previously represented a witness who was adverse to him on a felony charge. After disclosing the conflict, Alvarado’s attorney agreed that he and the public defender’s office would decline any future representation of the witness. However, Alvarado argued that counsel continued to have an actual conflict of interest because his ongoing ethical duties to the witness and former client prevented him from effectively cross- examining the witness. Alvarado contended this resulted in a structural defect in the trial, which necessitated overturning his convictions. In the alternative, Alvarado argued his unified aggregate sentence of twenty years to life for attempted strangulation and domestic abuse was excessive. After review, the Supreme Court determined Alvarado failed to show his counsel's representation constituted a fundamental error. He neither demonstrated an error affected the outcome of the trial, nor shown that a structural error denied him the right to counsel during a critical stage of the proceeding. Therefore, the Court ruled Alvarado was not deprived of his Sixth Amendment right to conflict-free counsel. The Court also held the district court did not abuse its discretion in sentencing Alvarado to a twenty-year to life aggregate sentence on his two felony convictions.
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