State v. Lopez

Summary

The Connecticut Supreme Court held that an in-chambers inquiry into a potential conflict of interest involving defense counsel was a critical stage of the defendant’s prosecution. Because the defendant was excluded from that inquiry, the court found a structural constitutional error requiring automatic reversal of the convictions without a specific showing of prejudice. The court affirmed the Appellate Court’s judgment ordering a new trial.

Holdings

1. An in-chambers inquiry into a potential conflict of interest involving defense counsel, conducted during trial, is a critical stage of the defendant's prosecution at which the defendant has a constitutional right to be present.
2. The trial court's exclusion of the defendant from the in-chambers conflict inquiry constituted structural error.
3. Because the defendant's exclusion was structural error, reversal was automatic and did not require a specific showing of harm or prejudice.
4. The Appellate Court correctly reversed the defendant's convictions and ordered a new trial, although the Supreme Court relied on the defendant's right to be present and structural error rather than deciding whether an actual conflict of interest existed.

Questions Presented

1. Whether the trial court's in-chambers inquiry into defense counsel's potential conflict of interest was a critical stage of the prosecution at which the defendant had a constitutional right to be present.
2. Whether excluding the defendant from that inquiry constituted structural constitutional error.
3. Whether reversal required a specific showing of harm or prejudice.
4. Whether the Appellate Court's judgment reversing the convictions and ordering a new trial should be affirmed.

Disposition

affirmed