Holloway v. Arkansas (1977)
- Docket
- 76-5856
- Decided
- 1977-01-01
Summary
Question: Does requiring a single attorney to represent multiple defendants deprive the defendants of their Sixth Amendment right to adequate assistance of counsel? Conclusion: Yes. Chief Justice Warren E. Burger delivered the opinion of the 6-3 majority. The Supreme Court held that a single lawyer representing multiple defendants does not automatically deprive the defendants of their rights, but it does if there is a conflict of interest. Because Hall showed that a conflict of interest was present, the trial court should have taken steps to appoint separate counsel or ensured that the risk of conflict was not great enough to require such action. The trial court did neither, so the defendants were deprived of their Sixth Amendment rights. The Court also held that, in such situations, the reversal of the conviction is automatic. In his dissenting opinion, Justice Lewis F. Powell, Jr. argued that the trial court’s failure to investigate the defense counsel’s claim that the interests of his clients conflict does not rise to level of a constitutional violation requiring reversal of the verdict. He argued that the majority’s opinion is based on the assumption that the jury will be prejudiced rather than on any evidence of a conflict. Justice Harry A. Blackmun and Justice William H. Rehnquist joined in the dissent.