State v. Stovall
298 Kan. 362
Kan.2013Background
- Stovall was charged with rape and related offenses involving his underage daughter.
- The district court appointed a public defender; three out-of-town motions to withdraw were filed by counsel over conflicts of interest.
- The district court denied the first two withdrawals and forced the conflicted attorney to continue, impairing attorney–client communication.
- A third withdrawal motion was denied; trial occurred; sentencing followed with continued conflicted representation.
- Court of Appeals found waiver for lack of prejudice argument and that the district court abused its discretion by not properly inquiring into conflicts.
- The Supreme Court reversed, holding the Sixth Amendment right to effective counsel was violated due to conflicts and remanded for a new trial with conflict-free counsel.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused discretion denying withdrawal motions. | Stovall—conflicts harmed representation and required withdrawal. | Stovall—district court failed to inquire into conflicts; compelled representation. | Yes; district court abused discretion by insufficient inquiry and denying withdrawals. |
| What standard applies when conflict of interest is unresolved at trial (automatic reversal vs. adverse effect). | Stovall—automatic reversal through Jenkins/Ryan framework. | State—apply Mickens/Galaviz adverse-effect framework. | Adverse-effect framework applies; court may reverse if conflict affected representation. |
| Is remand for new trial required given conflict-free counsel on remand. | Remand for new trial with conflict-free counsel. | Not necessary if merits could be addressed otherwise. | Remand with appointment of conflict-free counsel. |
| Does the sentencing proceeding (third withdrawal issue) support relief. | Sentence mis-management due to lack of effective counsel. | Court can proceed with sentencing despite conflict. | Yes; sentencing stage provided independent basis for relief under Cronic. |
Key Cases Cited
- Mickens v. Taylor, 535 U.S. 162 (U.S. (2002)) (tests for Sixth Amendment conflict of interest)
- Galaviz v. State, 296 Kan. 168 (2012) (three-subcategory Mickens framework; adverse effect option)
- Cheatham v. State, 296 Kan. 417 (2013) (conflict-based claims; applied adverse-effect test in third-subclass)
- Jenkins v. State, 257 Kan. 1074 (1995) (automatic reversal for actual conflict in certain scenarios)
- Jenkins v. State, 257 Kan. 1074 (1995) (automatic reversal for certain conflicts (pre-Mickens))
- State v. Vann, 280 Kan. 782 (2006) (requires inquiry into potential conflict; standard abuse of discretion)
- Boldridge v. State, 289 Kan. 618 (2009) (conflict of interest prejudice not required in all cases)
- State v. Carter, 284 Kan. 312 (2007) (conflict under KRPC; district court duties)