K. Briggs v. State

Summary

The Montana Supreme Court affirmed the denial of Briggs’s postconviction petition. It held that counsel’s withdrawal after an irreparable attorney-client breakdown did not constitute a structural denial of counsel or ineffective assistance, because counsel had previously provided substantial representation and the trial court promptly appointed replacement counsel. The court also held that appellate counsel was not ineffective for failing to challenge the absence of separate counsel at the withdrawal hearing because that hearing was not a critical stage presenting a substantial risk of prejudice.