Law School Case Brief
Mickens v. Taylor - 535 U.S. 162, 122 S. Ct. 1237 (2002)
Prejudice is presumed when a criminal defense counsel labors under an actual conflict of interest."Conflict of interest" means a division of loyalties that affected counsel's performance. An "actual conflict," for Sixth Amendment purposes, is a conflict of interest that adversely affects counsel's performance.
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 representedthe victim, Timothy 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, which an en banc majority of the Court of Appeals for 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.
Did the juvenile court’s judge failure to inquire into a potential conflict mandate automatic reversal of petitioner’s conviction?
The United States Supreme Court held that the juvenile court’s judge failure to inquire into a potential conflict did not mandate automatic reversal of petitioner’s conviction. According to the Court, 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. 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.
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