Cuyler v. Sullivan

Two private lawyers represented the respondent and two co-defendants facing murder charges. The respondent's trial took place first, with no objections raised about multiple representation. The defense rested its case after the prosecution, resulting in the respondent's conviction. The co-defendants were later acquitted in separate trials. The respondent sought collateral relief under Pennsylvania law, claiming ineffective assistance of counsel due to conflicting interests. The Pennsylvania Court of Common Pleas and Supreme Court denied relief, citing no evidence of multiple representation and a reasonable trial strategy. The respondent then pursued habeas corpus relief in the Federal District Court, which accepted the Pennsylvania Supreme Court's findings. However, the Court of Appeals for the Third Circuit disagreed, concluding that the involvement of the two lawyers in all three trials indicated a conflict of interest, violating the respondent's Sixth Amendment right to counsel.