Saturday, April 13, 2013

Wheat v. United States case brief

Wheat v. United States case brief summary
486 U.S. 153 (1988)

SYNOPSIS:
Petitioner sought review of a decision from the United States Court of Appeals for the Ninth Circuit, which affirmed his convictions for conspiracy to possess more than 1,000 pounds of marijuana with intent to distribute and possession of marijuana with intent to distribute, and upheld the district court's denial of petitioner's motion for substitution of counsel.

OVERVIEW: Petitioner appealed his convictions for conspiracy to possess more than 1,000 pounds of marijuana with intent to distribute and possession of marijuana with intent to distribute, contending the trial court erred in denying his motion for substitution of counsel and his offer to waive his right to conflict-free counsel. The trial court denied petitioner's motion, finding that an irreconcilable conflict of interest existed because it appeared that a co-defendant represented by the same attorney chosen by petitioner might be a witness in petitioner's trial, and petitioner might be called as a witness in the co-defendant's trial. The court of appeals affirmed the convictions and petitioner appealed.

HOLDING:
The court affirmed the convictions and the denial of petitioner's motion to substitute counsel, concluding that the denial was within the trial court's discretion and did not violate petitioner's rights under the Sixth Amendment.

ANALYSIS:
The court found that because the trial court found an actual conflict of interest there was no doubt that it had the right to decline petitioner's proffer of waiver of his right to conflict-free representation.

OUTCOME: The court affirmed the convictions of petitioner for conspiracy to possess more than 1,000 pounds of marijuana with intent to distribute and possession of marijuana with intent to distribute, and upheld the denial of his motion for substitution of counsel with a proffered waiver of his right to conflict-free counsel.

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