State v. Martinez-Castellanos

In this criminal case, the Supreme Court held that the court of appeals erred in accumulating errors that, standing alone, had no potential to cause harm, and thus reversed the court of appeals’ determination of cumulative error and remanded the case for the court of appeals to make a meritorious determination on Defendant’s motion to suppress.Defendant was convicted of two drug-related counts. After Defendant was convicted, the trial court stated that it was considering granting a new trial because of defense counsel’s ineffectiveness and appointed separate conflict counsel to represent Defendant on the issues it raised. The trial court declined to grant a new trial. Defendant appealed, asserting that his trial counsel provided ineffective assistance during the jury selection and motion stages and that the trial court erred in its dealings with conflict counsel. The court of appeals concluded that none of Defendant’s three claims of error warranted reversal on its own but that the cumulative effect of the errors warranted a new trial. The Supreme Court reversed, holding (1) the errors could not cumulate into reversible error; and (2) because the trial court did not determine whether the motion to suppress was meritorious, the case must be remanded to the court of appeals to make this determination. View "State v. Martinez-Castellanos" on Justia Law