Johnson v. State
948 N.E.2d 331
Ind.2011Background
- Johnson was convicted of Class A felony child molesting and sentenced to 35 years.
- Three months before trial, Johnson wrote to the judge alleging his public defender neglected his case.
- The judge forwarded the complaint to the Monroe County Public Defender's Office and took no further action.
- Trial occurred September 2–4, 2009; Johnson and his counsel participated; defense called only the defendant; proceedings yielded a guilty verdict.
- On appeal, the Court of Appeals rejected Johnson’s Sixth Amendment and prosecutorial misconduct claims; Johnson sought transfer to Indiana Supreme Court.
- The Supreme Court granted transfer and summarily affirmed the Court of Appeals on prosecutorial misconduct while addressing the Sixth Amendment claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial court inquiry violated Sixth Amendment | Johnson | Johnson | No Sixth Amendment violation; no inappropriate inquiry by court |
| Whether there was an actual or potential conflict of interest warranting Holloway/Sullivan inquiry | Johnson | Johnson | No actual or potential conflict; counsel’s neglect not a trigger |
| Whether the trial judge should have obtained assurances from the public defender's office | Johnson | Johnson | Duty to seek assurances exists; failure not prejudicial in this record |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong standard for ineffective assistance of counsel)
- Holloway v. Arkansas, 435 U.S. 475 (U.S. 1978) (conflict-of-interest framework for multiple representation)
- Cuyler v. Sullivan, 446 U.S. 335 (U.S. 1980) (actual conflicts and defendant’s right to conflict-free counsel)
- Wood v. Georgia, 450 U.S. 261 (U.S. 1981) (presumption against systemic conflicts; need for inquiry when appropriate)
- Glasser v. United States, 315 U.S. 60 (U.S. 1942) (duty to loyalty and conflicts of interest)
- Gideon v. Wainwright, 372 U.S. 335 (U.S. 1963) (right to counsel for indigent defendants)
- In re Schrems, 922 N.E.2d 618 (Ind. 2010) (public defender independence and disciplinary context in Indiana)