United States v. Corvet Williams, 2012 U.S. App. LEXIS 19030

Williams and Austin were tried jointly for armed bank robbery and use of a firearm in a crime of violence, convicted, retried after an earlier reversal, and received 684-month sentences.
Two nearly identical robberies occurred two weeks apart, with two masked black men (one short, one tall) using two stolen cars, one jumping the counter and the other confronting victims with a silver handgun.
Edward Walker testified as the getaway driver for the second robbery and identified the defendants; his testimony was supported by other witnesses including an ex-girlfriend of Austin and a barber who corroborated timing.
Austin argued the evidence was insufficient and challenged his counsel’s representation; the principal bar mustering items included alibi claims, alibi-related testimony, and the masked identification issues.
Williams challenged the use of his former lawyer as a trial witness for the government, contending it violated attorney‑client confidentiality and his Sixth Amendment rights; the court held the evidence admissible and, with harmless error analysis, affirmed the convictions and sentences.
The district court’s sentences remained within the scope of the post-Booker discretionary framework and were not overturned on vindictiveness grounds; the actions at retrial did not breach due process principles in the sentencing context.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence for Austin	Austin’s guilt rests on weak, circumstantial proof	Evidence linking Austin to both robberies is insufficient	Evidence sufficient beyond a reasonable doubt
Admissibility and impact of the former lawyer’s testimony against Williams	Lawyer’s testimony breached confidentiality and loyalty, violating Sixth Amendment rights	Testimony was permissible under professional rules and necessary to prosecution	No Fifth/Fourteenth Amendment violation; any error was harmless
Vindictiveness of the retrial sentence	Heavier second-trial sentence signals vindictiveness	Different judge and sentencing discretion justify the variation	Not vindictive; within permissible Booker-era discretion

Nix v. Whiteside, 475 F.3d 157 (7th Cir.1986) (1986) (attorney’s duty to dissuade a client from perjury)
Strickland v. Washington, 466 U.S. 668 (1984) (1984) (standard for ineffective assistance of counsel; performance and prejudice prongs)
N.D. Ill. Local Rule 83.51.6, (local rule referenced) (2007–) (professional conduct disclosure standards guiding duties to client and tribunal)
United States v. Duarte, 950 F.2d 1255 (7th Cir.1991) (1991) (cumulative evidence standard for reasonable doubt)
United States v. Carson, 702 F.2d 351 (2d Cir.1983) (1983) (cumulative probability of guilt standard)
Bobby v. Van Hook, 558 U.S. 4 (2009) (2009) (reaffirmed discretion in applying professional norms; guidelines not inexorable commands)
Hudson v. Michigan, 547 U.S. 586 (2006) (2006) (exclusionary rule costs of suppression; deterrence and social costs)