State v. Theisen

Summary

The court affirmed Theisen's convictions based on guilty pleas, holding that the amended information adequately alleged overt acts and that the factual basis established conspiratorial participation beyond the buyers and sellers necessary for the underlying drug offenses. Wharton's Rule therefore did not bar the conspiracy convictions, and counsel's failure to advise Theisen otherwise did not prejudice her. The court could not resolve her separate conflict-of-interest claim on direct appeal because the record lacked information about counsel's prior representation and its effect.