United States v. Williams, No. 15-12130 (11th Cir. 2018)Annotate this Case
Defendant appealed his conviction of a federal narcotics conspiracy offense, contending that his trial counsel had a conflict of interest that had an adverse effect on his performance at trial. The Eleventh Circuit held that counsel did have a conflict of interest when he represented a government witness who was then appealing his own sentence after pleading guilty to federal narcotics charges. Although counsel knew that the witness had been found to have obstructed justice in his own criminal case, counsel did not ask the witness about the obstruction scheme at defendant's trial. Therefore, the court remanded for the limited purpose of having the district court conduct an evidentiary hearing on whether counsel's conflict resulted in an adverse effect.
The court issued a subsequent related opinion or order on February 20, 2020.