Michael Hild v. United States

Whether the framework from Cuyler v. Sullivan, 446 U.S. 335 (1980)—where this Court held that a defendant alleging ineffective assistance of counsel based on a lawyer’s conflict of interest need not demonstrate outcome-determinative prejudice to obtain relief—applies only when a defense lawyer represents multiple clients with conflicting interests, or instead applies to other conflicts, such as personal conflicts of interest? If the Sullivan framework applies to personalinterest conflicts, whether—as endorsed by the Second Circuit below—a defendant seeking to prove an actual conflict must show that his counsel possessed a secret desire for conviction?