Steven Zapata v. Com., Kentucky Supreme Court,
To-be-published (4/27/2017):
Steven Zapata was charged with
murder. He pled guilty under North Carolina v. Alford and accepted
a 24-year sentence. He then moved to withdraw his plea. Appointed hybrid
co-counsel expressed discomfort and stood by unable to assist Mr. Zapata at the
hearing on his motion to withdraw his plea. The trial court refused to allow
him to withdraw his plea. On appeal, the Kentucky Supreme Court held that the
trial court erred by resolving an involuntary plea issue without an evidentiary
hearing and without appointing conflict-free counsel.
Susan Balliet
represented Mr. Zapata on appeal.