United States v. Angel Rodriguez, Juan Carlos Fernandez, Raphael Guelbenzo, Jesus Rodriguez, Santiago Rodriguez

Attorney Peter Golburgh defended three brothers — Angel, Lazare and Santiago Rodriguez — charged in a wide-ranging marijuana importation and distribution conspiracy. The jury acquitted Lazaro, but found Angel and Santiago guilty on some of the counts. On appeal, Angel and Santiago argue that the joint representation violated their rights to effective counsel. 1 Because the defendants fully consented to this joint representation at a pre-trial hearing, we AFFIRM.

Factual and Procedural Background

Before the start of the conspiracy trial, the district court tried to make certain that the three…