 Glasser was " the Supreme Court 's first vehicle for the examination of joint representation . " The Court continued to deal with this issue in Dukes v. Warden ( 1972 ) , Holloway v. Arkansas ( 1978 ) , Cuyler v. Sullivan ( 1980 ) , Burger v. Kemp ( 1987 ) , Wheat v. United States ( 1988 ) , and Mickens v. Taylor ( 2002 ) . 
