The following excerpt is from Manning v. Foster, 224 F.3d 1129 (9th Cir. 2000):
In these cases we examined only whether the conflict of interest between the habeas petitioner and counsel constituted a denial of the Sixth Amendment right to counsel. See supra. That is because conflict of interest claims are usually considered under the rubric of the Sixth Amendment right to counsel. See Strickland v. Washington, 466 U.S. 668, 688 (1984).
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