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Laurell Wells v. United States

IFP petition · United States Court of Appeals for the Second Circuit, No. 24-76 · judgment March 9, 2026


Certiorari denied · October 5, 2026

Question presented

A defendant in a criminal case is entitled to conflict-free counsel. Wheat v. United States, 486 U.S. 153, 162-63 (1988). In the Second Circuit, the test for whether a criminal defendant can waive his defense lawyer’s conflict is whether “the conflict is of such a serious nature that no rational defendant would knowingly and intelligently desire that attorney’s representation.” United States v. Schwarz, 283 F.3d 76, 95 (2d Cir. 2002). The Fifth Circuit, by contrast, rejects waivers in cases where a conflict “is so severe as to render a trial inherently unfair [such that] the integrity of the judicial system has been undermined.” United States v. Vaquero, 997 F.2d 78, 90 (5th Cir. 1993). The question for this Court is which test should apply in a case where the defendant’s lawyer labors under an ethical conflict (in this case, the lawyer simultaneously represented the corporate victim of the crime on lucrative unrelated matters): one that focuses on the perspective of a hypothetical rational defendant or one that focuses on system integrity?

Counsel of record

For petitioner
JaneAnne Murray
Murray Law LLC

For respondent
D. John Sauer
Solicitor General

Case

Subject area
Criminal Procedure (estimated from the questions presented, in the Supreme Court Database’s categories)

Conference history
Distributed for 1 conference

Order
Order list, October 5, 2026 · Certiorari denied

Proceedings

  1. Oct 05 2026
    Petition DENIED.
  2. Sep 03 2026
    DISTRIBUTED for Conference of 9/28/2026.
  3. Aug 31 2026
    Waiver of right of respondent United States to respond filed.
  4. Aug 11 2026
    Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due September 21, 2026)