In the 1987 case Wheat v. United States, the U.S Supreme Court upheld a lower court's decision to deny a defendant's choice of counsel due to potential conflicts of interest. The defendant, Wheat, was indicted on various drug charges and wished to retain an attorney who had previously represented his co-defendants in related cases. The District Court denied this request citing concerns about possible conflicts of interest that could arise from representing multiple defendants involved in interconnected crimes. Upon appeal, the Ninth Circuit reversed this decision arguing that unless actual conflict is demonstrated by objecting co-defendants or evidence from trial proceedings itself, such disqualification should not occur. The Supreme Court however disagreed with the Ninth Circuit’s ruling and reinstated the original judgment stating that federal courts must be allowed substantial latitude in refusing waivers of right to counsel based on potential conflict situations for ensuring fair trials. It held that while Sixth Amendment guarantees a defendant’s right to choose their own legal representation; it does not grant unlimited authority over appointment process which remains subject to court supervision.

In the dissenting opinion for Wheat v. United States, it was argued that a defendant's right to choose his own counsel should not be overridden by potential conflicts of interest unless those conflicts are severe and cannot be waived by the client. The dissenting justices believed that Michael Wheat had been denied this fundamental Sixth Amendment right when he was prevented from retaining an attorney who had previously represented co-defendants in related cases. They contended that any potential conflict could have been mitigated through proper court procedures or waivers, and thus did not justify denying Wheat his choice of representation. Furthermore, they expressed concern over giving judges too much discretion in determining what constitutes a serious enough conflict to override a defendant's rights.