Mickens v. Taylor

Mickens (defendant) was convicted of premeditated murder and sentenced to death. His court-appointed lead trial attorney, Saunders, had represented the murder victim, Hall, in an unrelated matter just three weeks before Hall was killed, then was appointed to represent Mickens without disclosing this prior representation; Mickens learned of it later when a clerk mistakenly sent Hall's file to his federal habeas counsel. On habeas review, the district court held an evidentiary hearing but denied relief, and the court of appeals assumed the trial judge had failed a duty to inquire into the potential conflict but still held Mickens had to show the conflict actually and adversely affected his representation, which he failed to do.