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84 Wis. 2d 11

267 N.W.2d 586

State v. Medrano

Wisconsin Supreme Court

Decided June 30, 1978

Wisconsin Supreme Court · decided 1978-06-30

Relies on Holloway v. Arkansas · Campbell v. United States · 78 Wis. 2d 189 - Harrison v. State

Good law ✅— No negative treatment on recordhow we know

Decided 1978-06-30

How this case has been cited

Cited by 26 later decisions — most recently June 2019 · most notably 86 Wis. 2d 459 - State v. Wollman (1979), 87 Wis. 2d 253 - State v. Koller (1979)

26 state decisions

10019781980199020002010decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

SHIRLEY S. ABRAHAMSON, J.

¶1(concurring). The majority correctly concludes on the basis of standards set out in our prior cases that Medrano did not establish that he was denied effective representation by counsel. However, after reviewing Holloway v. Arkansas, — U.S. —, 98 Sup. Ct. 1173, 55 L. Ed.2d 426 (filed April 3, 1978), and our prior decisions involving an attorney’s representation of multiple defendants, I am concerned that the majority opinion does not emphasize the need for the attorney to avoid, wherever possible, multiple representation, and does not set forth the responsibility of the trial court to insure that defendants understand the risks of multiple representation.

¶2The majority opinion repeats what we have often said: “The fact that one attorney represents more than one defendant is not in itself a conflict of interest and the attorney is entitled to represent more than one defendant unless the interest of the defendants is shown to be in conflict.” Unfortunately this statement does not reflect the court’s deep concerns and misgivings about multiple representation. Whenever there is multiple representation, there is the danger of conflict of interest. Therefore, the general rule which must guide the attorney is that the attorney should decline to act for more than one of several co-defendants.

¶3Section 3.5 (b) of the American Bar Association Standards Relating to the Defense Function, provides in part:

*30“The potential for conflict of interest in representing multiple defendants is so grave that ordinarily a lawyer should decline to act for more than one of several co-defendants except in unusual situations when, after careful investigation, it is clear that no conflict is likely to develop and when the several defendants give an informed consent to such multiple representation.”

¶4The Commentary to sec. 3.5(b) also emphasizes that lawyers should undertake multiple representation only in the rare circumstance in which such representation is clearly required.

“. . . Although there may be some situations where it will be mutually advantageous to the defendants to have a single lawyer represent them, the risk of an unforeseen and even unforeseeable conflict of interest developing is so great that a lawyer should decline multiple representation unless there is no other way in which adequate representation can be provided to the defendants.”

¶5Similarly, the Code of Professional Responsibility does not explicitly proscribe multiple representation, but it strongly admonishes against the practice and urges lawyers to resolve all doubts against the propriety of multiple representation. Code of Professional Responsibility, EC 5-14 to 5-17, DR 5-101, 43 Wis.2d xlii-xlv.

¶6If lawyers heed these admonitions, a case involving multiple representation should be a rare occurrence.1

¶7If there is multiple representation, a question arises as. to the duty of the trial judge to assure that criminal defendants are not deprived of their right to the effective *31assistance of counsel guaranteed by the state and federal constitutions. See. 3.4(b) of the American Bar Association Standards Relating to the Administration of Criminal Justice — The Function of the Trial Judge places an affirmative duty on the trial judge in the event of multiple representation:

“Sec. 3.4(b) Whenever two or more defendants who have been jointly charged, or whose cases have been consolidated, are represented by the same attorney, the trial judge should inquire into potential conflicts which may jeopardize the right of each defendant to the fidelity of his counsel.”

¶8This court has neither accepted nor rejected the rule adopted by the Standards and by some courts2 that the trial court has an affirmative obligation to ascertain whether defendants are aware of the potential risks involved in the multiple representation. Harrison v. State, 78 Wis.2d 189, 205, 254 N.W.2d 220 (1977). I believe the court should adopt such a rule and I urge the trial courts to assume this obligation in the interests of efficient judicial administration and the protection of the constitutional rights of defendants.3

¶9 For a proposal to interpret the Code to prohibit an attorney from representing multiple defendants in a criminal matter, see Geer, Representation of Multiple Criminal Defendants: Conflicts of Interest & The Professional Responsibilities of the Defense Attorney, 62 Minn. L. Rev. 119 (1978).

¶10Mr. Justice Powell, in his dissenting opinion in Holloway v. Arkansas, — U.S. - -, n. 2 and text (April 3, 1978), summarizes the disadvantages of a rule prohibiting all multiple representation.

¶11 The federal courts of appeal have differed with respect to the scope and nature of the affirmative duty of the trial judge. Holloway v. Arkansas, — U.S. —, — (April 3, 1978).

¶12 In Campbell v. United States, 352 F.2d 359 (D.C. Cir. 1965), the trial court’s duty was described as follows:

“An individual defendant is rarely sophisticated enough to evaluate the potential conflicts .... Considerations of efficient judicial administration as well as important rights of defendants are served when the trial judge makes the affirmative determination that co-defendants have intelligently chosen to be represented by the same attorney and that their decision was not governed by poverty and lack of information on the availability of assigned counsel. We must indulge every reasonable presumption against the waiver of the unimpaired assistance of counsel.” (at 360-61)
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