Dukes v. Warden, Connecticut State Prison

Defendant was charged with various narcotics violations and larceny. After a brief hospital stay due to a suicide attempt, he entered a plea of guilty on advice of counsel. Prior to sentencing, Defendant asked the court to withdraw his plea and stand trial, and informed the court he had retained new counsel. The Court denied this request and sentenced him consistent with the plea’s agreed-upon recommendation of the State’s attorney. Defendant appealed to the Connecticut Supreme Court, challenging the voluntariness of his plea on the grounds that he had just left the hospital and was not fully conscious of the details of his plea. The Connecticut Supreme Court affirmed his conviction and the U.S. District Court for the District of Connecticut denied his application for habeas corpus relief. Defendant brought a state habeas corpus action in the Superior Court of Hartford County asserting, for the first time, that his attorney had a conflict of interest because he was also representing two of Defendant’s co-defendants in an unrelated case and had argued, in that unrelated case, that Defendant was the reason for his co-defendants’ plight. The Superior Court denied relief, and the Supreme Court of Connecticut affirmed. The Supreme Court of the United States gave extreme deference to the record of proceedings below and affirmed the decisions of the Connecticut court, concluding that the record showed Defendant had never expressed dissatisfaction with his counsel, although he was fully aware of his dual representation; Defendant’s counsel’s dual representation did not result in ineffective assistance or ineffective negotiations of his plea; and there was no evidence that Defendant’s counsel gave misleading advice in order to further goals in the unrelated case.

“There is nothing in the record before us which would indicate that the alleged conflict resulted in ineffective assistance of counsel and did in fact render the plea in question involuntary and unintelligent. [Petitioner] does not claim, and it is nowhere indicated in the finding, nor could it be inferred from the finding, that [Attorneys] induced [petitioner] to plead guilty in furtherance of a plan to obtain more favorable consideration from the court for other clients. . . . Neither does the finding in any way disclose, nor is it claimed, that [petitioner] received misleading advice from [Attorneys] which led him to plead guilty. The court did not err in concluding that [petitioner’s] plea was not rendered involuntary and unintelligent by the alleged conflict of interest.” p.256-257