State v. Edwards
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After a jury trial, Richard Edwards was found guilty of deliberate homicide. The Supreme Court affirmed the judgment of the district court, holding (1) the district court did not err when it permitted Edwards' wife's testimony because (a) her observations of Edwards' actions did not constitute spousal communications and therefore were not privileged, and (b) Edwards' marital communications regarding the murder that were accompanied by threats were not privileged because they were not communicated in reliance on the confidence of the marital relationship; (2) Edwards was not denied effective assistance of counsel because he failed to show he was prejudiced by defense counsel's admission of lack of preparation for cross-examination; and (3) while it was error for the district court not to inquire into Edwards' post-trial motion for new counsel, reversal in this case was not required because Edwards did not allege a conflict that resulted in a total lack of communication, nor did he claim that his attorneys were unable or unwilling to represent him at the sentencing hearing.
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