Does Sullivan's standard apply only when a defense lawyer represents multiple clients with conflicting interests, or does Sullivan apply to other conflicts—such as personal conflicts of interest?

QUESTION PRESENTED In Cuyler v. Sullivan, 446 U.S. 335 (1980), this Court held that a defendant alleging ineffective assistance of counsel based on a lawyer’s conflict of interest need not demonstrate prejudice to obtain relief. Instead, a defendant need only show that an “actual conflict of interest adversely affected his lawyer’s performance.” Id. at 350. The question presented is: Does Sullivan’s standard apply only when a defense lawyer represents multiple clients with conflicting interests (as eleven jurisdictions have held), or does Sullivan apply to other conflicts—such as personal conflicts of interest (as twenty-one jurisdictions have held)? (i)