Cited by

Opinions in Minnesota that cite State v. Paige, 765 N.W.2d 134.

39 citing documents.

State of Minnesota v. Stevie Ray Samaniego Minn. Ct. App. 2026
(quotation omitted); (“A lawyer’s performance is deficient if he represents a client despite having a conflict of interest.”).
State of Minnesota v. Brandon Marquies Jones Minn. Ct. App. 2025
Criminal defendants have the right to assistance of counsel, and “[t]his right includes a fair opportunity to secure counsel of [their] own choice.”
Roosevelt Bartu, Jr. v. State of Minnesota Minn. Ct. App. 2025
“The right to counsel includes the right to effective assistance of counsel.”
State of Minnesota v. Michael Drew Williams Minn. Ct. App. 2024
“A conflict of interest exists if ‘there is a significant risk that the representation of one or more clients will be materially limited by 23 the lawyer’s responsibilities to another client , a former client or a third person , or by a personal interest of the lawyer.’” (quoting Minn. R. Prof.
State of Minnesota v. Aaron Lee Gant Minn. Ct. App. 2023
(explaining that a district court must ascertain how a defendant wishes to proceed following discharge of counsel and then determine whether the defendant may proceed as requested).
State of Minnesota v. Saliou Kouyate Minn. Ct. App. 2023
The right to effective assistance of counsel includes a “correlative right” to conflict-free counsel, Wood v. Georgia, 450 U.S. 261, 271 (1981), and a defendant can establish the deficient performance prong of Strickland by demonstrating that counsel had a conflict of interest, .
State of Minnesota v. Randy Terrell Mayberry Minn. Ct. App. 2022
State of Minnesota v. Shanin Trevon English Minn. Ct. App. 2021
“A lawyer’s performance is deficient if he represents a client despite havi ng a conflict of interest.”
State of Minnesota v. Willie III Wair Minn. Ct. App. 2021
d 27, 32 (Minn. App. 1997), review denied (Minn. Aug.
State of Minnesota v. Brandon Michael James Opatz Minn. Ct. App. 2020
A defendant cannot demand a continuance for the purpose of delay or by “arbitrarily choosing to substitute counsel at the time of trial.” ().
Igor Pavlovich Albantov v. State of Minnesota Minn. Ct. App. 2020
State of Minnesota v. Bruce Renault Fry Minn. Ct. App. 2020
Fry argues that his case is like State v. Paige, in which this court reasoned that a district court should ask a defendant how he wishes to proceed when he wants to discharge his attorney, and that the district court erred 20 when it “took no action to clarify appellant’s request to discharge counsel.” d 134, 140 (Minn. App. 2009).
State of Minnesota v. Dominique Demetris Wright Minn. Ct. App. 2020
(concluding that district court erred by failing to determine how defendant wished to proceed after discharging counsel and remanding “to clarify and address [defendant’s] request to discharge counsel”).
State of Minnesota v. Micheal Anthony Sparks Minn. Ct. App. 2019
Appellant also relies on State v. Paige , , for the proposition that the district court should have asked how appellant intended to proceed pro se .
State of Minnesota v. Pedro Antonio Lawler Minn. Ct. App. 2019
“[W]hen an attorney informs the district court of a probable risk of conflict, and the court fails to take adequate steps to ascertain whether an impermissible conflict exists , the defendant’s conviction mu s t b e r e v e r s e d w i t h o u t inquiry into prejudice resulting from the alleged conflict.” -41 (Minn. App. 2009) (quotation omitted).
State of Minnesota v. Kevin Hall Minn. Ct. App. 2019
See State v. Paige , (remanding to district court with instructions to allow appellant to renew plea -withdrawal request after court resolves his request to discharge counsel based on ineffective assistance).
State of Minnesota v. Geovany Gonzalez Bernia Minn. Ct. App. 2018
State of Minnesota v. Wayne Joseph Bosto Minn. Ct. App. 2018
to support his argument that the district court erred by failing to appoint substitute 8 counsel.
State of Minnesota v. Desmond Lamart Jones Minn. Ct. App. 2017
The court bears “the responsibility to clarify and address a defendant’s request to discharge counsel.”
State of Minnesota v. Ricky Donell Holifield Minn. Ct. App. 2016
State of Minnesota v. Melissa Rae Guillette Minn. Ct. App. 2016
State of Minnesota v. Ricky Donell Holifield Minn. Ct. App. 2016
If a defendant establishes a conflict of interest, prejudice is “generally presumed.”
State of Minnesota v. Melissa Rae Guillette Minn. Ct. App. 2016
“[W]hen a criminal defendant makes a request to discharge counsel, the district court is required to first ascertain how the defendant wishes to proceed after counsel is discharged, and then determine whether it is appropriate for the defendant to proceed as requested.”
Jeffrey Edward Morey v. State of Minnesota Minn. Ct. App. 2016
Jeffrey Edward Morey v. State of Minnesota Minn. Ct. App. 2016
“A lawyer’s performance is deficient if he represents a client despite having a conflict of interest.” (citing Wood v. Georgia, 450 U.S. 261, 271-72, 101 S. Ct. 1097, 1103-04 (1981)); see also Minn. R. Prof.
State of Minnesota v. Scott Richard Seelye Minn. Ct. App. 2016
State of Minnesota v. Scott Richard Seelye Minn. Ct. App. 2016
Instead, a district court may terminate a self-represented litigant if he “deliberately engage[s] in serious and obstructionist misconduct,” “abuse[s] the dignity of the courtroom,” Faretta, 422 U.S. at 834 n.46, or where self-representation unduly delays or disrupts trial, -40 (Minn. App. 2009).
State of Minnesota v. Sedne Bonitaz Williams Minn. Ct. App. 2016
State of Minnesota v. Sedne Bonitaz Williams Minn. Ct. App. 2016
For purposes of demonstrating ineffective assistance of counsel, “[a] lawyer’s performance is deficient if he represents a client despite having a conflict of interest.”
Larry Dean Mensing v. State of Minnesota Minn. Ct. App. 2015
Larry Dean Mensing v. State of Minnesota Minn. Ct. App. 2015
“A lawyer’s performance is deficient if he represents a client despite having a conflict of interest.”
State of Minnesota v. Jeffrey Nicholas Aase Minn. Ct. App. 2015
State of Minnesota v. Jeffrey Nicholas Aase Minn. Ct. App. 2015
- 141 (Minn. App. 2009) (noting that “a defendant who raised no objection at trial must demonstrate that defense counsel actively represented conflicting interests and [that] this conflict adversely affected the lawyer’s performance,” but that where a defendant makes the district court aware of a probable conf
State of Minnesota v. Kai Yang Minn. Ct. App. 2014
State of Minnesota v. Kai Yang Minn. Ct. App. 2014
“A lawyer’s performance is deficient if he represents a client despite having a conflict of interest.”
State of Minnesota v. Samuel Johosephat Taylor Minn. Ct. App. 2014
State of Minnesota v. Samuel Johosephat Taylor Minn. Ct. App. 2014
Finally, to argue that the district court should have rescheduled the plea-withdrawal hearing to permit Taylor to retain a different lawyer.
State v. Patterson 796 N.W.2d 516 Minn. Ct. App. 2011
State v. Patterson 796 N.W.2d 516 Minn. Ct. App. 2011
(using definition provided by rules of professional conduct to determine whether trial attorney had a conflict that violated defendant’s constitutional right to counsel).