Cuyler v. Sullivan

Two private lawyers represented Sullivan (respondent) and two co-defendants on murder charges, with no objection to the multiple representation. Sullivan was tried first; the defense rested after the prosecution's case, and he was convicted, while the co-defendants were later acquitted in separate trials. Sullivan sought post-conviction relief for ineffective assistance based on the conflicting representation. State courts denied relief; the federal district court accepted their findings, but the Third Circuit found a disqualifying conflict.

Whether a defendant is denied effective assistance of counsel by a conflict of interest where one lawyer represents both the defendant and a co-defendant and neither objected to the multiple representation.