Steven Zapata v. Commonwealth of Kentucky

Summary

The Kentucky Supreme Court held that Zapata was denied conflict-free counsel during his pre-sentencing motion to withdraw his Alford plea because his appointed attorney declined to assist him while facing allegations concerning her own conduct. The court also held that the trial court should have conducted an evidentiary hearing because Zapata presented a colorable claim of involuntariness, and that hybrid-counsel status did not eliminate his right to effective counsel. The court vacated the judgment and the order denying withdrawal of the plea, while leaving the plea itself intact pending further proceedings.