USA v. Bellille

The defense counsel made this interlocutory appeal based on the District Court’s denial of his motion to withdrawal. Defense counsel was appointed to a RICO case pursuant to the Criminal Justice Act (CJA). He moved to withdraw, as he joined a firm as “of counsel” and the primary attorney at that firm represented a cooperating witness in the same action. The 3rd Circuit reviewed Model Rules of Professional Conduct 1.7 (conflicts of interest and current clients), and 1.10 (imputation of conflicts of interest). The Court remanded for more fact finding, as the record was insufficient to resolve the issue.