162
OCTOBER TERM, 2001
Syllabus
certiorari to the united states court of appeals for the fourth circuit
No. 00-9285. Argued November 5, 2001—Decided March 27, 2002
A Virginia jury convicted petitioner of the premeditated murder of Timothy Hall during or following the commission of an attempted forcible sodomy, and sentenced petitioner to death. Petitioner filed a federal habeas petition alleging, inter alia, that he was denied effective assistance of counsel because one of his court-appointed attorneys had a conflict of interest at trial. Petitioner's lead attorney, Bryan Saunders, had represented Hall on assault and concealed-weapons charges at the time of the murder. The same juvenile court judge who dismissed the charges against Hall later appointed Saunders to represent petitioner. Saunders did not disclose to the court, his co-counsel, or petitioner that he had previously represented Hall. The District Court denied habeas relief, and an en banc majority of the Fourth Circuit affirmed. The majority rejected petitioner's argument that the juvenile court judge's failure to inquire into a potential conflict either mandated automatic reversal of his conviction or relieved him of the burden of showing that a conflict of interest adversely affected his representation. The court concluded that petitioner had not demonstrated adverse effect.
Held: In order to demonstrate a Sixth Amendment violation where the trial court fails to inquire into a potential conflict of interest about which it knew or reasonably should have known, a defendant must establish that a conflict of interest adversely affected his counsel's performance. Pp. 166-176.
(a) A defendant alleging ineffective assistance generally must demonstrate a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been different. Strickland v. Washington, 466 U. S. 668, 694. An exception to this general rule presumes a probable effect upon the outcome where assistance of counsel has been denied entirely or during a critical stage of the proceeding. The Court has held in several cases that "circumstances of that magnitude," United States v. Cronic, 466 U. S. 648, 659, n. 26, may also arise when the defendant's attorney actively represented conflicting interests. In Holloway v. Arkansas, 435 U. S. 475, the Court created an automatic reversal rule where counsel is forced to represent co-defendants over his timely objection, unless the trial court has determined that there is no conflict. In Cuyler v. Sullivan, 446 U. S. 335,
Page: Index 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: October 4, 2007