Attorney Bernard J. O’Donnell had two clients facing the death penalty. In one case, the trial court imposed the death penalty against O’Donnell’s client despite the jury’s 2-10 vote rejecting it. O’Donnell appealed, arguing the trial court erred in failing to give the jury’s vote “great weight.” In the second case, against Joseph Williams (defendant) for first-degree murder, the jury voted exactly the opposite: 10-2 in favor of the death penalty. O’Donnell moved to withdraw and asked the court to appoint substitute counsel. O’Donnell asserted that Williams could raise an argument on appeal that the trial court erroneously concluded it was required to give “great weight” to the jury’s 10-2 vote recommending the death penalty—a position directly contradictory to O’Donnell’s other death-penalty appeal. O’Donnell urged that representing both clients could create unfavorable precedent for either one client or the other, as well as undermine O’Donnell’s credibility and his clients’ perception of his loyalty. The prosecution agreed that conflict of interest disqualified O’Donnell from representing Williams on appeal.