The following excerpt is from United States v. Walter-Eze, 869 F.3d 891 (9th Cir. 2017):
"An actual conflict need not be a direct conflict, and it need not be established separately from adverse effect. Instead, an actual conflict is a conflict of interest that adversely affects counsel's performance. " Hovey v. Ayers , 458 F.3d 892, 908 (9th Cir. 2006) (quoting
[869 F.3d 901]
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