What is the test for establishing a conflict of interest under the Sixth Amendment?

Under the Sixth Amendment, "[w]here a constitutional right to counsel exists, ... there is a correlative right to representation that is free from conflicts of interest." Woodv. Georgia , 450 U.S. 261, 271, 101 S.Ct. 1097, 67 L.Ed.2d 220 (1981). To establish a Sixth Amendment violation based on a conflict of interest, "a defendant who raised no objection at trial must demonstrate that an actual conflict of interest adversely affected his lawyer's performance." Cuyler v. Sullivan , 446 U.S. 335, 348, 100 S.Ct. 1708, 64 L.Ed.2d 333 (1980). An "actual conflict" means "a conflict of interest that adversely affects counsel's performance," rather than "a mere theoretical division of loyalties."

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