State v. Norman

In State v. Norman, 151 N.J. 5, 23, 697 A.2d 511 (1997), the Court once again read the Bellucci holding narrowly and refused to apply its per se rule to cases beyond those in which attorneys are clearly associated in practice. 151 N.J. at 30, 697 A.2d 511. Outside these "well-defined cases," the Norman Court applied the "more flexible approach" devised in Bell. Id. at 25, 30, 697 A.2d 511. In examining the conflict of interest and evaluating the likelihood of prejudice, the Court in Norman found that the partnership negotiations and shared office space arrangement in that case did not give rise to a presumption of prejudice where the attorneys otherwise conducted their affairs separately by having "separate phones, secretaries, files, and bank accounts." 151 N.J. at 26, 697 A.2d 511.