Re v. U.S.

Dist. Ct. did not err in denying defendant’s habeas petition challenging his conviction under Hobbs Act for using extortion measures to injure third-party’s business, even though defendant argued that co-counsel’s theft of defendant’s money three weeks after defendant’s conviction demonstrated that co-counsel labored under conflict of interest that required new trial without need to show prejudice. Post-trial crime by defendant’s co-counsel did not spoil defendant’s trial as matter of law without showing of prejudice, and record showed lack of prejudice where: (1) co-counsel, whose work at trial was supervised by another co-counsel, played only minor role in defendant’s trial; (2) other co-counsel did majority of work at defendant’s trial; and (3) defendant never alleged that other co-counsel labored under conflict of interest.