State v. EasonAnnotate this Case
The Supreme Court reversed the postconviction court’s summary denial of Appellant’s pro se petition for postconviction relief, in which Appellant argued that his trial counsel was ineffective and that the prosecutor improperly refused to renew her initial plea offer.
Appellant was convicted of first-degree felony murder. After Appellant filed his pro se petition for postconviction relief, Appellant asked the postconviction court to appoint counsel. The postconviction court referred Appellant’s request for counsel to the state public defender, which declined to represent Appellant. The district court then denied Appellant’s postconviction petition without holding an evidentiary hearing. The Supreme Court reversed, holding (1) Appellant was entitled to an appointed attorney for postconviction proceedings because he did not have a “review” on direct appeal; and (2) therefore, the postconviction court erred in not granting Appellant’s request for counsel.