146 L.Ed.2d 389 (2000)). What matters are the holdings of the Supreme Court, not the holdings of lower federal courts. B. Supreme Court Jurisprudence In Cuyler v. Sullivan, the Supreme Court stated that “until a defendant shows that his counsel actively represented conflicting interests, he has not established the constitutional predicate for his claim of ineffective assistance.” 446 U.S. at 350, 100 S.Ct. 1708. In other words, in order to succeed on a claim based on an alleged conflict, there must be a showing of an actual conflict, namely that a defendant’s attorney is representing conflicting interests. Conflicting interests have been recognized by the Supreme Court in a variety of settings. See, e.g., Mickens v. Taylor, 535 U.S. 162, 164-65, 122 S.Ct. 1237, 152 L.Ed.2d 291 (2002) (<HOLDING>); Wood v. Georgia, 450 U.S. 261, 270-72, 101
recognizing the conflict recognizing a potential conflict of interest when appointed counsel previously represented the murder victim in a separate case holding that the defendant was deprived of his sixth amendment right to counsel where appointed counsels representation presented a conflict of interest recognizing a potential conflict when defense counsel is currently representing in another matter either the victim of the crime or a prosecution witness recognizing conflict