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Sanford v. Commonwealth of Virginia

United States District Court for the Eastern District of Virginia

687 F. Supp. 2d 591 (2009)

Relevant factsFree

John Sanford, a disabled hospital patient, became delirious after post-surgical medication and died after being restrained facedown and handcuffed on the floor for roughly 30 minutes by hospital security, police officers, and a sedative injection from a nurse. Sanford's estate (plaintiffs) sued numerous hospital employees and police officers (defendants); one attorney represented all the hospital-employee defendants as a group and another represented all the police-officer defendants as a group. As testimony developed, conflicting accounts and differing theories of individual culpability emerged within each group, prompting the estate to move to disqualify both defense attorneys.

IssueFree

Whether an attorney representing multiple clients in the same action must withdraw from representing more than one of them if severe and pervasive conflicts of interest arise.

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