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BEETS v. COLLINS
United States Court of Appeals, Fifth Circuit (1993) | 986 F.2d 1478
TL;DR: A defendant convicted of capital murder claimed her attorney had a conflict of interest for failing to testify on her behalf and for taking media rights as payment. The court reversed a grant of habeas corpus, finding no actual conflict that adversely affected counsel's performance.
Legal Significance: This case clarifies the standard for ineffective assistance of counsel claims based on an attorney's personal conflict of interest, holding that a defendant must show the conflict was actual, not merely potential, and that counsel actively chose their own interests to the client's detriment.