A defendant who was excluded from an in-chambers meeting to determine whether his counsel had a conflict of interest was not entitled to habeas relief. The defendant here challenged his California conviction on the ground that his counsel had a conflict of interest because he was being prosecuted by the same office that was prosecuting his case, and further argued that his due process rights were violated when he was excluded from in camera hearings on the matter. The Ninth Circuit affirmed the denial of habeas relief on the former ground, noting that the California Court of Appeal had presumed a conflict of interest but found no prejudice. The court further denied relief on due process grounds, again finding no possible prejudice from the exclusion. Two judges dissented, finding that the exclusion from the in-chambers hearing was a structural defect that was inherently prejudicial.
Case Summaries