Guzman v. State

In Guzman v. State, 644 So. 2d 996 (Fla. 1994), the Court reversed a defendant's conviction for first-degree murder and his death sentence because the trial court erroneously denied the public defender's motion to withdraw based on conflicts of interest between Guzman and other clients of the public defender's office. Id. at 997. The Court concluded that once a public defender moves to withdraw under section 27.53(3), Florida Statutes (2007) based on a conflict due to adverse or hostile interests between two clients, the trial court must grant separate representation. Id. at 999. Under Guzman v. State, courts must allow withdrawal when the public defender certifies "that the interests of one client are so adverse or hostile to those of another client that the public defender cannot represent the two clients without a conflict of interest." In Guzman our supreme court was construing section 27.53(3), Florida Statutes (1991), and that opinion left trial courts with no discretion when a public defender filed a motion to withdraw alleging conflict. The statute was recently amended by the addition of the following language: The court shall review and may inquire or conduct a hearing into the adequacy of the public defender's representations regarding a conflict of interest without requiring the disclosure of any confidential communications. The court shall permit withdrawal unless the court determines that the asserted conflict is not prejudicial to the indigent client. Ch. 99-282, 1, at 3084, Laws of Fla.