Ward
United States v. Ward
Opinion
Lead Opinion
MEMORANDUM *
Steven Ward was convicted of conspiring with his son, John, to launder the proceeds of John’s drug trafficking enterprise. At trial, Ward was represented by his son’s former attorney Thomas Wright. The government moved to disqualify Wright on the ground that conflicts of interest would prevent Wright from effectively representing Ward, but Ward vigorously opposed the motion and offered to waive the conflicts. Ward now argues that the court violated his Sixth Amendment right to conflict-free counsel when it accepted his waiver. 1 We have jurisdiction pursuant to 28 U.S.C. § 1291 , and we affirm.
Trial courts have substantial latitude when determining whether or not to accept *190 a defendant’s waiver of a conflict of interest. 3 Wheat v. United States, 486 U.S. 153, 164 , 108 S.Ct. 1692 , 100 L.Ed.2d 140 (1988) (noting that “[t]he evaluation of the facts and circumstances of each case ... must be left primarily to the informed judgment of the trial court”). Conflicts of interest between an attorney and client are waivable unless they are “so egregious that no rational defendant would knowingly and voluntarily desire the attorney’s representation.” United States v.…