Law School Case Brief
Wheat v. United States - 486 U.S. 153, 108 S. Ct. 1692 (1988)
While the right to select and be represented by one's preferred attorney is comprehended by the Sixth Amendment, the essential aim of the Amendment is to guarantee an effective advocate for each criminal defendant rather than to ensure that a defendant will inexorably be represented by the lawyer whom he prefers.
Defendant Mark Wheat was one of 14 defendants charged on counts relating to a marijuana importation and distribution scheme that spanned nearly three years. Co-defendants Javier Bravo and Juvenal Gomez-Barajas were also part of the scheme. At separate trials in federal district court, Wheat was represented by counsel of his choice; Bravo and Gomez-Barajas were represented by attorney Eugene Iredale. Bravo ultimately pleaded guilty to count one of the indictment. Later, at the time of Wheat's trial, the district court was considering Gomez-Barajas' offer to plead guilty to certain charges. Two days before his trial was to commence, Wheat filed a motion to have Iredale substituted as his counsel. Over Wheat's assertion of his Sixth Amendment right to the counsel of his choice, and his willingness, as well as that of Gomez-Barajas and Bravo, to waive the right to conflict-free counsel, the district court denied the substitution motion. The district court determined that irreconcilable and unwaiveable conflicts of interest existed because of the likelihood that Wheat would be called to testify at any subsequent trial of Gomez-Barajas, and that Bravo would testify at Wheat's trial. Wheat proceeded to trial with his original counsel and was convicted. On Wheat's appeal, the court of appeals affirmed. Wheat was granted a writ of certiorari.
Did the trial court's denial of Wheat's motion for substitution of counsel violate Wheat's Sixth Amendment right to counsel?
The Supreme Court of the United States affirmed the appellate court's judgment. The Court noted that in cases where an attorney sought to represent multiple codefendants, a district court must be allowed substantial latitude in refusing defendants' waivers of their Sixth Amendment right to conflict-free representation, not only where an actual conflict may be demonstrated before trial, but also where there was a potential for conflict that could develop into an actual conflict as the trial progressed. In the present case, the district court's refusal to permit the requested substitution of counsel was within its discretion and did not violate Wheat's Sixth Amendment rights.
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