United States v. Watts

MEMORANDUM **

We review for abuse of discretion1 Watts’s claim that the disqualification of his counsel violated his Sixth Amendment rights,2 and find none. The district court correctly found “that there is the potential for conflict of interest.”3 The district court’s stray remark about the “appearance” of a conflict of interest does not detract from its finding. We need not decide whether screening might be appropriate in some criminal case,4 because the district court found that screening did not eliminate the potential conflict in this case.5 That ruling was within the district court’s…