745 F.3d 1231
D.C. Cir.2014Background
- Wright appealed his 8-year sentence after pleading guilty to possession with intent to distribute cocaine.
- Wright was charged in 1992 with Washington and Early; Washington and Early were convicted in 1992-1993.
- Wright disappeared on bail, later captured in 2008 and brought to D.C. for trial.
- Attorney Wood, who represented Wright, discovered potential conflict from representing Washington previously; conflict-free counsel Wicks assisted.
- Record shows Wright pled guilty voluntarily after consulting with Wicks; Wright received an eight-year sentence; Wright now challenges Wood’s alleged conflict as ineffective assistance of counsel.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Conflict arising from successive representation? | Wright argues Wood’s prior representation of Washington created an adverse conflict. | Wood’s representation did not adversely affect Wright; conflict was addressed by Wicks and plea was voluntary. | No adverse effect shown; conviction affirmed under Cuyler/Mickens framework. |
| Was Wright’s guilty plea coerced? | Wright contends coercion by Wood. | Plea was voluntary; coercion not shown. | Plea voluntary based on record evidence. |
Key Cases Cited
- Cuyler v. Sullivan, 446 U.S. 335 (1980) (conflict-of-interest standard; adverse effect not always required)
- Mickens v. Taylor, 535 U.S. 162 (2002) (open question on applying Cuyler to successive representation)
- United States v. Berkeley, 567 F.3d 703 (D.C. Cir. 2009) (status of Cuyler applicability to successive representation remains unresolved)
- United States v. Bruce, 89 F.3d 886 (D.C. Cir. 1996) (conflict claims as a genre of ineffective assistance)
- United States v. Thompson, 721 F.3d 711 (D.C. Cir. 2013) (record conclusively rebuts ineffective-assistance claim)