Michael Gonzales, Petitioner v. State of South Carolina, Respondent

Summary

The South Carolina Supreme Court reversed the Court of Appeals, holding that a petitioner need not prove that counsel recognized an actual conflict of interest to obtain relief in a post‑conviction claim of ineffective assistance of counsel. The Court affirmed that once an actual conflict is shown and it adversely affected counsel’s performance, prejudice is presumed under Cuyler and Strickland.