Wheat v. United States (1987)
- Docket
- 87-4
- Decided
- 1987-01-01
Summary
Question: Did the district court violate Wheat’s Sixth Amendment right to his choice of counsel by refusing to permit Wheat’s additional counsel due to a possible conflict of interest? Conclusion: No. In a 5-4 decision written by Justice William Rehnquist, the Court held that the possible conflict of interest was sufficient to justify denying Wheat’s motion to take on Iredale as his attorney. Justice Rehnquist noted that the Sixth Amendment right to choice of counsel was limited in several ways; for example, a party could not hire a lawyer who had a previous or ongoing legal relationship with the opposing party. He also noted that the Court previously recognized that the representation of multiple defendants by the same lawyer created special dangers of conflict of interest, although it was not a per se constitutional violation. Although Wheat insisted that the waivers by all defendants cured any problems from multiple representations, Justice Rehnquist wrote that the federal courts had an independent interest in fair and ethical criminal trials. Justice Rehnquist reasoned that courts had the latitude to decline defendants’ waivers where the potential for a conflict of interest existed. Here, the persons Iredale wished to represent were allegedly three conspirators at various levels in a complex drug distribution operation, and there remained a possibility that either Bravo or Gomez-Barajas could be a witness at Wheat’s trial. Thus, Justice Rehnquist held that rejecting Wheat’s motion was within the district court’s discretion. Justice Thurgood Marshall dissented, joined by Justice William Brennan. He argued that the majority granted unwarranted deference to the district court’s discretion, and that the potential for a conflict of interest in the case did not outweigh Wheat’s Sixth Amendment right to his choice of counsel. Justice John Paul Stevens dissented, joined by Justice Harry Blackmun. He emphasized that Wheat’s prior counsel planned to remain available to assist with his defense. Hence, the question was actually whether Wheat had the right to the additional counsel of his choice.