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Name: Sanchez v. Superior Court
Case #: E083015
Division: 2
Opinion Date: 20241108
Summary

No error where trial court removed defendant’s deputy public defender from the case, over defendant and counsel’s objection, due to conflict of interest based on counsel’s alleged potential RJA violation (PC 745). Defense counsel allegedly told the prosecutor to offer defendant a better plea bargain because the prosecutor and defendant were from the same racial group. Defense counsel has a duty to investigate any potential RJA violation, but investigating one’s own potential unconscious bias is not possible, creating an actual conflict justifying counsel’s removal. Dissent deemed removal unwarranted because no conceivable RJA violation occurred.

The full opinion is available on the court’s website here: https://www.courts.ca.gov/opinions/documents/E083015.PDF