Wheat v. United States Case Brief

Why is the case important?

Petitioner, Wheat, desired to hire Iredale, the attorney who was already representing two other defendants to various crimes all arising out of the same course of events. The District Court denied petitioner’s request, citing conflict of interest, and petitioner appealed.

Facts of the case

“For many years, Mark Erick Wheat allegedly participated in a far-flung marijuana distribution operation, acting mainly as an intermediary by receiving and storing shipments of marijuana in his home then distributing them around the region. Juvenal Gomez-Barajas and Javier Bravo were also allegedly involved in the operation. Attorney Eugene Iredale represented Gomez-Barajas and Bravo at trial. The trial court acquitted Gomez-Barajas on drug charges that overlapped with charges against Wheat, but Gomez-Barajas pleaded guilty to tax evasion and illegal importation of merchandise to avoid a second trial. At the beginning of Wheat’s trial, however, the court had not yet accepted Gomez-Barajas’ plea and he was free to withdraw it.On August 22, 1985, Bravo pleaded guilty to one count of transporting 2,400 pounds of marijuana. Immediately after the proceedings, Iredale informed the court that Wheat contacted him to hire him as additional counsel

  • Gomez-Barajas and Bravo waived any objection. The United States expressed concern about the possibility of conflict arising from Iredale’s representation of both Iredale and Gomez-Barajas. The government pointed out that if Gomez-Barajas withdrew his plea, it was likely Wheat would be required to appear at his trial as a witness. In that event, Iredale would not be allowed to cross-examine Wheat. Further, it was possible that Bravo would be required to appear at Wheat’s trial as a witness as well.Although Wheat emphasized his right to his choice of counsel under the sixth amendment, the district court denied his motion for a substitution of counsel. Wheat was convicted of conspiracy to possess 1,000 pounds of marijuana with intent to distribute and five counts of possessing marijuana with intent to distribute. The United States Court of Appeals, Ninth Circuit, affirmed. It held that the district court correctly balanced the sixth amendment’s rights to choice of counsel and to a defense by an attorney free of conflicts of interest.”

    Question

    Whether the Sixth Amendment right to counsel allows a defendant to waive the right to conflict-free counsel, in order to obtain the counsel of his choosing.

    Answer

    Affirmed. Chief Justice Rehnquist delivered the opinion of the court, noting that the Sixth Amendment right to choose one’s own counsel is often circumscribed by the right to effective assistance of counsel. Particularly, as in this case, it is at the discretion of the District Court to determine whether certain counsel could offer effective representation and, should the court decide it cannot, the court has the right to abrogate the defendant’s wishes.

    Conclusion

    The Supreme Court of the United States affirmed the appellate court’s judgment. The Court noted that in cases where an attorney sought to represent multiple codefendants, a district court must be allowed substantial latitude in refusing defendants’ waivers of their Sixth Amendment right to conflict-free representation, not only where an actual conflict may be demonstrated before trial, but also where there was a potential for conflict that could develop into an actual conflict as the trial progressed. In the present case, the district court’s refusal to permit the requested substitution of counsel was within its discretion and did not violate Wheat’s Sixth Amendment rights.

    • Case Brief: 1988
    • Petitioner: Mark Erick Wheat
    • Respondent: United States
    • Decided by: Rehnquist Court

    Citation: 486 US 153 (1988)
    Argued: Mar 2, 1988
    Decided: May 23, 1988
    Granted Oct 5, 1987