In re Personal Restraint of Richardson
In In re Personal Restraint of Richardson, 100 Wn.2d 669, 677, 675 P.2d 209 (1983), defense counsel had represented a defense witness whose testimony created a self-incrimination issue.
The Court adopted two rules.
First, a trial court commits reversible error if it knows or reasonably should know of a particular conflict and fails to inquire.
Second, reversal is always necessary where a defendant shows an actual conflict of interest adversely affecting counsel's performance.
These rules apply to any situation where defense counsel represents conflicting interests. Richardson, 100 Wn.2d at 677.