Cuyler v. Sullivan case brief summary
446 U.S. 335 (1980)
CASE FACTS
Defendant and his co-defendants were indicted for first-degree murder. Two lawyers represented all three defendants throughout the trial. Defendant did not object to the multiple representation. Defendant was convicted while his co-defendants were acquitted. The lower appellate court found that both lawyers had represented defendant, and that reversal was required because there was a possibility of a conflict of interest in that representation.
DISCUSSION
CONCLUSION
The court vacated the lower appellate court's decision and remanded for further proceedings.
Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure
446 U.S. 335 (1980)
CASE SYNOPSIS
The court granted certiorari on a
judgment from the United States Court of Appeals for the Third
Circuit, which reversed defendant's conviction for first-degree
murder and held that defendant's U.S. Constitutional Amendment
VI rights had been violated when two lawyers had represented
defendant and his two co-defendants, and there was a showing of some
possible conflict of interest in that representation.CASE FACTS
Defendant and his co-defendants were indicted for first-degree murder. Two lawyers represented all three defendants throughout the trial. Defendant did not object to the multiple representation. Defendant was convicted while his co-defendants were acquitted. The lower appellate court found that both lawyers had represented defendant, and that reversal was required because there was a possibility of a conflict of interest in that representation.
DISCUSSION
- The court vacated, holding that state courts were not required to inquire into the sufficiency of multiple representation where no parties objected and no special circumstances were present.
- Where defendant raised no objection at the trial to the sufficiency of the multiple representation, he was required to show that an actual conflict of interest adversely affected his lawyer's performance.
- A possible conflict of interest was not enough to establish an ineffective assistance of counsel.
CONCLUSION
The court vacated the lower appellate court's decision and remanded for further proceedings.
Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure
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