People v. Jackson
167 Cal.App.3d 829, 213 Cal. Rptr. 521, 1985 Cal. App. LEXIS 2029 (1985)
Rule of Law:
An undisclosed, ongoing romantic relationship between a defense attorney and a prosecutor in a criminal case creates a potential conflict of interest that requires reversal of the conviction without a showing of actual prejudice to the defendant.
Facts:
- The defendant was charged with assault with intent to commit rape.
- His court-appointed defense counsel was in an ongoing 'dating' relationship with the prosecutor assigned to the case.
- The relationship had begun approximately eight months before the defendant was charged and continued throughout the criminal proceedings.
- The attorneys met regularly for movie and dinner dates, representing a sustained personal relationship.
- Neither the defense counsel nor the prosecutor disclosed their relationship to the defendant or to the court.
- The defendant was unaware of the relationship until after the conclusion of his trial.
Procedural Posture:
- A jury convicted the defendant of assault with intent to commit rape and use of a deadly weapon in the state trial court.
- After the verdict but before sentencing, the defendant discharged his court-appointed trial counsel and retained new counsel.
- Through new counsel, the defendant filed a motion for a new trial, alleging ineffective assistance of counsel due to the undisclosed relationship.
- The trial court conducted an evidentiary hearing on the motion.
- The trial court denied the motion for a new trial and imposed a sentence.
- The defendant (appellant) appealed the judgment to the California Court of Appeal.
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Issue:
Does a court-appointed defense attorney's failure to disclose an ongoing romantic relationship with the prosecutor to the defendant constitute a conflict of interest that requires reversal of the defendant's conviction?
Opinions:
Majority - Puglia, P. J.
Yes. A defense attorney's failure to disclose a romantic relationship with the prosecutor requires reversal. Under the California Constitution, a defendant's right to effective assistance of counsel requires undivided loyalty, and even a potential conflict of interest may necessitate reversal if the record supports an 'informed speculation' that the right was prejudicially affected. An apparently close and sustained dating relationship between opposing counsel reasonably gives rise to speculation that professional judgment has been compromised, as counsel may be subject to subtle influences, such as a reluctance to engage in abrasive confrontation. This situation creates an appearance of impropriety that undermines public confidence in the justice system. Therefore, counsel had a duty to fully disclose the relationship to the defendant, and the failure to do so requires reversal without indulging in 'nice calculations as to the amount of resulting prejudice.'
Analysis:
This decision establishes that a personal, romantic relationship between opposing counsel can constitute a reversible conflict of interest, extending the doctrine beyond traditional financial or multiple-representation conflicts. It solidifies California's stringent standard, which focuses on potential conflicts and the appearance of impropriety, contrasting with the federal standard that typically requires proof of an actual conflict that adversely affected representation. The ruling creates a bright-line requirement for disclosure in such situations, placing the burden on the attorneys to inform their clients of relationships that could compromise zealous advocacy. This prioritizes the client's right to conflict-free counsel and public confidence in the judicial system over inquiries into whether the conflict caused actual harm.
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