Taylor v. Grounds

Federal 7th Circuit Court
Criminal Court
Conflict of Interest
Citation
Case Number: 
No. 12-2632
Decision Date: 
July 3, 2013
Federal District: 
N.D. Ill., E. Div.
Holding: 
Reversed and remanded
Dist. Ct. erred in denying defendant’s habeas petition challenging his murder conviction on ground that his trial counsel labored under conflict of interest while jointly representing defendant and his brother in said trial when counsel declined to present testimony from certain potential witnesses, who countered state’s claim that defendant had handed gun to his brother prior to shooting, where counsel believed that such testimony would be harmful to brother’s case. State court unreasonably found that defendant’s interest in presenting said exculpatory witnesses did not conflict with his brother’s interest in preventing said testimony from being introduced at trial. On remand, Dist. Ct. must conduct hearing to determine whether instant conflict of interest adversely affected trial counsel’s representation of defendant, or whether other factors unrelated to conflict of interest led to counsel’s decision not to introduce exculpatory evidence, such as criminal backgrounds of such witnesses that could have rendered their testimonies incredible.