Shongutsie v. State
In Shongutsie v. State, 827 P.2d 361 (Wyo. 1992), the Court held that, in conflict of interest cases involving one attorney's representation of multiple defendants, we would not follow the minimal federal standard under the Sixth Amendment of requiring an appellant to show prejudice by such multiple representation if he had failed to object in the trial court.
Instead, the Court chose to enlarge the right to effective assistance of counsel under Wyo. Const. art. 1, 10 by holding that prejudice would be presumed in all instances of such multiple representation. Shongutsie, 827 P.2d at 366-67.