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Name: Young v. Runnels
Case #: 03-16859
Court: US Court of Appeals
District 9 Cir
Opinion Date: 01/23/2006

Unbeknownst to Young, during his trial his retained counsel had state bar disciplinary proceedings pending and also had filed a lawsuit against numerous public officials, including the district attorney of the county that was prosecuting Young. Counsel was eventually disbarred. The appellate court affirmed the district court’s denial of a habeas corpus petition, holding that the district court correctly applied Strickland v. Washington, 466 U.S. 668 (1984) rather than United States v. Cronic, 466 U.S. 648 (1984) to Young’s ineffective assistance of counsel claim because counsel’s eventual disbarment was not a constructive denial of counsel. It further held Young suffered no prejudice from counsel’s representation because the plea offers that Young had first rejected but later wanted to accept were off the table by the time retained counsel entered the case. Finally, the court held Young waived the conflict-of-interest claim caused by counsel suing the district attorney because Young did not raise this issue in the district court. Judge Noonan’s concurrence detailed how counsel was obviously incompetent yet still fully licensed during Young’s trial, but concluded the outcome was correct under the case law from the U.S. Supreme Court.