The State of Washington v. Paramjit Singh Dhaliwal

Summary

The court affirmed Dhaliwal's convictions, holding that although the trial court inadequately investigated counsel's potential conflicts and Dhaliwal did not waive his conflict-free-counsel right, he failed to show that an actual conflict adversely affected counsel's performance. The court also held that the prosecutor's references to Sikh culture and religion were supported by the evidence and, in any event, were not so inflammatory that an objection and curative instruction could not have prevented prejudice. The court declined to decide whether the Washington Constitution provides greater protection because Dhaliwal did not adequately brief the required state constitutional analysis.