In People v. Easley (1988) 46 Cal.3d 712, it was clear that counsel's interests in representing the two parties were in conflict: Plankington must show that Easley had committed arson for hire, while Easley wanted to show that he was not a criminal. ( Id. at pp. 720, 725.) The court found persuasive an analysis of whether non-conflicted counsel would have proceeded differently than the manner chosen by the allegedly conflicted counsel. ( Id. at p. 729.)