09/23/2026
Conflicts of Interest in Large Multi-Defendant Cases: A General Overview
This week, the Sangamon County State's Attorney announced a RICO indictment charging 23 people from two rival Springfield groups. Each defendant is charged with one count of RICO
conspiracy, an offense that carries up to 30 years in prison, and up to life for defendants whose actions allegedly resulted in death. Every person charged is presumed innocent. This post does not comment on the facts of the case or on any individual. It explains, in general terms, a practical issue that large multi-defendant cases often raise: conflicts of interest for defense
attorneys.
In Illinois, a defense attorney owes each client undivided loyalty. Under Illinois Rule of Professional Conduct 1.7, a lawyer generally cannot represent one person if that representation is directly adverse to another current client, or if duties owed to someone else would limit the defense. When members of rival groups are charged in the same case, one defendant may be an
alleged victim of conduct attributed to another. Illinois courts treat a lawyer's simultaneous representation of a defendant and the alleged victim as an automatic conflict, without any need to show that it actually affected the defense.
Conflicts can also arise from past work. A lawyer who previously represented someone who later becomes a witness may be limited in cross-examining that person. If a defendant decides to cooperate with the prosecution, lawyers connected to more than one person in the case may
be required to withdraw.
Public defender offices face the same issues on a larger scale. Illinois courts do not automatically treat a public defender's office as a single law firm for conflict purposes; instead, potential conflicts are reviewed case by case. When the public defender cannot represent a particular defendant, Illinois law (725 ILCS 5/113-3) provides for the court to appoint other
counsel. In a mid-sized county such as Sangamon, the number of attorneys who regularly handle serious felony matters is limited, and many may have prior connections to people involved in a case of this size. For that reason, conflict screening in cases like this is often extensive and may continue as the case develops.
Conflict rules exist to protect the fairness of the proceedings and the right of every accused person to effective, loyal representation. They are an ordinary and important part of how the justice system handles complex cases.
This post is provided for general informational and educational purposes only. It is not legal advice, is not
an advertisement or solicitation for legal services, and does not create an attorney-client relationship. It is
not intended to invite contact regarding this or any other matter. Nothing in this post should be relied upon with respect to any specific case or individual
