Derrington v. United States

SCHWELB, Associate Judge:

Anthony Derrington was convicted of selling crack cocaine to an undercover officer. He contends on appeal that his trial attorney, Douglas Wood, Esq., had a disqualifying conflict of interest and that Wood’s performance was otherwise constitutionally deficient. The government responds that any conflict of interest was hypothetical or speculative, and that Wood’s representation of Derrington satisfied constitutional standards. Concluding that an actual conflict of interest adversely affected Wood’s representation, we reverse.

I

BACKGROUND

On December 4, 1991, Derrington…