v. Leggett, 81 F.3d 220, 227 (D.C.Cir.1996) (“[W]e are unpersuaded by [the petitioner’s] further attempt to style his disagreement with counsel over trial tactics as a ‘conflict of interest.’ ”); Stenson v. Lambert, 504 F.3d 873, 886 (9th Cir.2007) (“We can find no clearly established Supreme Court precedent holding that [a disagreement over trial strategy] amounts to an actual conflict of interest.”); United States v. Jones, 662 F.3d 1018, 1026-27 (8th Cir. 2011) (“[The Sixth Amendment] is not violated by general dissatisfaction or disagreements over strategy....”). Because these disagreements with Mr. Sheffield did not create a conflict of interest, Mr. Howell is only entitled to relief if he can establish prejudice under Strickland. See Burger, 483 U.S. at 783, 107 S.Ct. at 3120 (<HOLDING>). In my opinion, Mr. Howell has not met that
holding that prejudice is only presumed if there is proof of an actual conflict of interest recognizing conflict holding the existence of a possible conflict required remand for a determination of whether an actual conflict of interest existed and holding a new trial would be required if an actual conflict existed holding that to demonstrate that a conflict of interest violated his sixth amendment rights a defendant must establish that an actual conflict of interest adversely affected his lawyers performance holding that an assertion of prejudice is not a showing of prejudice