In Sherwood v. State, 493 P.3d 230 (Alaska Ct. App. 2021), the court of appeals held that the lower court erred in dismissing the defendant’s application for post-conviction relief, because it was plain error for the court to accept the defendant’s attorney’s certificate of no arguable merit when the attorney had a clear conflict of interest. (Id. at 231–32). The defendant was represented by the same attorney during his direct appeal of assault convictions and during post-conviction relief proceedings based on claims of ineffective assistance of counsel. (Id. at 231). The attorney filed a certificate of no arguable merit, asserting that the defendant had no non-frivolous claims for post-conviction relief and affirming that he had no conflict of interest in representing the defendant. (Id.). The lower court accepted the certificate and dismissed the post-conviction relief application, and the defendant appealed. (Id.). The court of appeals found that because the attorney has a personal interest in defending the professional competency of his own representation, the attorney had an obvious conflict of interest under Alaska Rule of Criminal Procedure 35.1(e)(2)(C). (Id. at 231–32). The court of appeals held that because of the conflict of interest, the attorney was prohibited from filing a certificate of no merit, and the defendant was entitled to new, conflict-free counsel during his post-conviction relief proceedings. (Id. at 233).