Holloway v. Arkansas

A single appointed attorney, Hall, represented three co-defendants, including Holloway (defendant), in the same criminal case and warned the trial court twice before trial that conflicting information from each client could create conflicts of interest if all three testified; the trial court denied his motions for separate counsel each time. At trial, all three defendants testified, and Hall, constrained by the conflict, could not conduct meaningful direct examination and instead let each present unguided testimony denying involvement; all three were convicted, and their state-court appeals on ineffective-assistance grounds failed before the U.S. Supreme Court granted review.