Williams v. Ludwick, No. 13-1978 (8th Cir. 2014)
Annotate this CasePetitioner, convicted of first degree murder and sentenced to life imprisonment, appealed the district court's denial of his petition for habeas relief. Assuming without deciding that Cuyler v. Sullivan applied to conflict of interest not arising out of multiple representation, the court held that petitioner failed to demonstrate that he was entitled to relief where trial counsel's conflict of interest did not adversely affect his performance. Petitioner also failed to demonstrate that appellate counsel was ineffective by failing to press arguments outside the scope of remand. Accordingly, the court affirmed the judgment of the district court.
Court Description: Prisoner case - Habeas. The Iowa courts did not err in rejecting Williams' claims that conflicts of interest rendered his trial counsel ineffective as he failed to establish that the conflicts adversely affected the representation he received; with respect to claims that appellate counsel was ineffective, the case Williams relies on to establish ineffective assistance of counsel did not apply to the facts of his case.
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