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Edwards v. Lewis

The defendant's trial and appellate counsel were laboring under an actual conflict of interest, when they represented defendant, and they allowed the conflict of interest to affect their representation of the defendant in significant ways.

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In 2002, Michael Edwards filed a pro se petition for writ of habeas corpus challenging his 2001 conviction for cocaine possession. According to Edwards, his trial and appellate attorneys provided constitutionally ineffective assistance of counsel because they were laboring under an actual conflict of interest that significantly affected their representation of him. The habeas court denied the petition after finding that there was no actual conflict of interest. We granted Edwards’s application for a certificate of probable cause to appeal and now reverse. 1. In January 2001, a DeKalb County grand jury indicted Edwards for possession of cocaine with intent to distribute. Edwards’s trial counsel filed a motion challenging the racial composition of the grand and traverse jury arrays.1 The trial court denied the motion, and on May 2, 2001, a DeKalb County jury convicted Edwards of the lesser-included offense of simple possession of cocaine. Based on Edwards’s status as a recidivist offender, the trial court sentenced him to 15 years in prison. The trial court denied Edwards’s motion for a new trial, and on February 20, 2002, the Court of Appeals affirmed his conviction.2

On December 6, 2002, Edwards filed a pro se petition for writ of habeas corpus in the Baldwin County Superior Court. Edwards alleged that his trial and appellate attorneys, both of whom were employed by the public defender’s office, were laboring under an actual conflict of interest that significantly affected their representation of him, thereby depriving him of his constitutional right to counsel. The habeas court conducted an evidentiary hearing on February 19, 2003, at which Edwards’s trial and appellate counsel testified.

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