Can a defendant bring a conflict of interest claim in a Rule 32 post-conviction review?
MultiRegion, United States of America
The following excerpt is from Murdaugh v. Ryan, 2:09-CV-00831-FJM, No. 10-99020 (9th Cir. 2013):
Murdaugh's claim is not procedurally defaulted because he did not violate a state procedural rule. Arizona courts treat conflict of interest claims as a species of ineffective assistance of counsel claims. See, e.g., State v. Jenkins, 715 P.2d 716, 718-19 (Ariz. 1986) (en banc). And Arizona law only permits defendants to bring ineffective assistance of counsel claims in Rule 32 post-conviction review
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