State v. BaconAnnotate this Case
The Supreme Court affirmed the decision of the court of appeals ruling that Petitioner's pro se motion quoting Kansas Rules of Professional Conduct (KRPC) 1.3 did not trigger the district court's duty to inquire into a potential conflict between Petitioner and his appointed attorney, holding that, assuming error, there was no showing of prejudice.
Petitioner was charged with two counts of commercial sexual exploitation of a child. The district court determined that Petitioner was indigent and appointed a public defender to represent him. The jury found Defendant guilty of one count of commercial sexual exploitation of a child. Thereafter, Petitioner filed a motion for a new trial, arguing that the district court erred by failing to inquire into his pro se motions voicing dissatisfaction with counsel. The district court denied the motion on the grounds that Petitioner's pro se documents did not convey a request for new counsel. The court of appeals affirmed, concluding that Petitioner's pro se motions quoting KRPC 1.3 did not allege dissatisfaction with counsel. The Supreme Court affirmed, holding that, assuming that the district court abused its discretion when it failed to inquire about Petitioner's dissatisfaction with counsel, Petitioner's alleged conflict with counsel did not prejudice Defendant in any way.