MICKENS v. TAYLOR, WARDEN 535 U.S. 162 (2002) CASE BRIEF

MICKENS V. TAYLOR, WARDEN

535 U.S. 162 (2002)

NATURE OF THE CASE: This was a dispute over effective assistance at trial.

FACTS: A Virginia jury convicted Mickens (D) of the premeditated murder of Timothy Hall during or following the commission of an attempted forcible sodomy. D was sentenced to death. D filed a petition for writ of habeas corpus alleging, inter alia, that he was denied effective assistance of counsel because one of his court-appointed attorneys had a conflict of interest at trial. Federal habeas counsel had discovered that D's lead trial attorney, Bryan Saunders, was representing Hall (the victim) on assault and concealed-weapons charges at the time of the murder. Saunders had been appointed to represent Hall, a juvenile, on March 20, 1992, and had met with him once for 15 to 30 minutes some time the following week. Hall's body was discovered on March 30, 1992, and four days later a juvenile court judge dismissed the charges against him, noting on the docket sheet that Hall was deceased. The one-page docket sheet also listed Saunders as Hall's counsel. On April 6, 1992, the same judge appointed Saunders to represent D. Saunders did not disclose to the court, his co-counsel, or petitioner that he had previously represented Hall. Under Virginia law, juvenile case files are confidential and may not generally be disclosed without a court order, but D learned about Saunders' prior representation when a clerk mistakenly produced Hall's file to federal habeas counsel. The habeas petition was denied. The Court of Appeals assumed that the juvenile court judge had neglected a duty to inquire into a potential conflict, but rejected D's argument that this failure either mandated automatic reversal of his conviction or relieved him of the burden of showing that a conflict of interest adversely affected his representation. The court held that a defendant must show 'both an actual conflict of interest and an adverse effect even if the trial court failed to inquire into a potential conflict about which it reasonably should have known.' Concluding that D had not demonstrated adverse effect, it affirmed the District Court's denial of habeas relief.

ISSUE:

RULE OF LAW:

HOLDING AND DECISION:

LEGAL ANALYSIS:

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