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The Little Rock attorney who represented all three members of the Manson family charged in Marion County’s rape cases has moved to withdraw from every one of them, citing a conflict of interest.
Six days later, the Marion County Sheriff’s Office raided the family’s County Road 8054 property and arrested Steven L. Manson Sr. on new felony drug and firearm charges. He has since bonded out.
No new attorney has entered an appearance in any of the cases, according to the court docket. That leaves Manson Sr., his son Steven M. Manson Jr. and Dezarae Manson unrepresented on the record with a status hearing set for Aug. 18.
Eugene P. Clifford filed his motion to withdraw in Manson Sr.’s case, 45CR-26-14, on July 24 at 3:30 p.m. He filed the same motion in the family’s other cases.
The two-page filing gives one reason. It states that a conflict of interest has arisen that requires him to withdraw under Rule 1.7 of the Arkansas Rules of Professional Conduct.
The motion adds that Manson Sr. knows of the decision and is looking for new representation. It says no money is owed to Clifford and that he has begun refunding unused portions of the retainer. Clifford did not describe the nature of the conflict, and attorneys are generally barred from disclosing client confidences.
Manson Sr., 56, of Yellville, was booked into the Marion County jail at 11:11 a.m. on July 30. The jail roster lists three charges: possession of a Schedule VI controlled substance with the purpose to deliver, a felony; possession of a firearm by certain persons; and habitual offender. Bond was set at $50,000.
Schedule VI in Arkansas covers marijuana and THC products. Booking charges are not the same as the charges a prosecutor files, and no new case had appeared on the docket as of Monday.
What Rule 1.7 means
Rule 1.7 is the conflict rule that governs a lawyer’s current clients. It says a lawyer cannot represent a client when the representation is directly adverse to another client, or when there is a significant risk that duties to one client will materially limit what the lawyer can do for another.
Some conflicts can be waived. The client has to give informed consent, and the consent has to be confirmed in writing.
Others cannot be waived at all. A lawyer may not keep representing clients when one is asserting a claim against another in the same proceeding, or when the lawyer can no longer give each client competent and diligent representation.
None of that makes it improper for one attorney to defend co-defendants. Courts have said for decades that joint representation is allowed and can even help defendants who share a common defense. The risk is what it stops a lawyer from doing.
A lawyer defending three people cannot argue that one of them is less responsible than the others. He cannot negotiate a deal for one client that hurts a second. He cannot cross-examine a client who takes the stand against another client.
Arkansas produced the leading case on the subject. In Holloway v. Arkansas, decided in 1978, one public defender represented three men charged together with robbery and rape. He told the trial judge he could not represent their competing interests, the judge did not look into it, and the U.S. Supreme Court threw out all three convictions without requiring proof that anyone was actually harmed.
That automatic remedy is narrow. The Supreme Court later held in Mickens v. Taylor that it applies only when the lawyer raises the conflict with the trial judge. Otherwise a convicted defendant has to show that a real conflict actually damaged his defense.
No one raised the issue in Marion County. Neither Deputy Prosecuting Attorney John Russo nor Prosecuting Attorney David Ethredge objected on the record to one attorney representing all three co-defendants, and the docket shows no hearing on the question.
That silence matters going forward. Everything Clifford filed between March and July, including the request to move Manson Jr.’s trial, was filed by a lawyer who now says a conflict prevented him from continuing. If any of the three is convicted, those months become an issue on appeal.
Clifford’s withdrawal is what the rule requires once a conflict develops, and the Observer is not alleging that he acted improperly. A lawyer in that position generally has to step away from all of the affected clients rather than drop one and keep the rest, which is what the filings show he did.
He also carries obligations to all three as former clients. He cannot represent any of them against the others, and he cannot use or reveal what they told him.
The practical effect falls on the calendar. New attorneys will have to start over on six cases and a court record that already includes 318 pages of exhibits on one pretrial motion alone.
Nothing in the filings explains what changed between April and July.
Conflicts of this kind rarely appear out of nowhere in a criminal case. They surface when co-defendants stop lining up. A defendant who agrees to a plea, gives a statement to investigators or prepares to testify against someone charged alongside him creates a problem one lawyer cannot solve for both sides.
Conflicts can also arise for reasons that have nothing to do with a defendant’s position. A fee dispute, a lawyer’s own interest or an unexpected witness can each force a withdrawal. Clifford cannot say which applies here, and the prosecutor’s office has declined comment on the cases for months.
What the record shows is the order of events. Clifford filed on July 24. Deputies searched the County Road 8054 property on July 30 and arrested Manson Sr. on charges that have nothing to do with the rape cases.
The sheriff’s office had known about that property for years, as the Observer has documented. Deputies searched it six days after the family’s defense arrangement collapsed.
A search of a private home generally requires a warrant supported by probable cause, which means new information presented to a judge.
Any shift in the posture of the three rape cases would appear on the public docket. As of Monday, none had been filed.
How the cases got here
Both Manson men arrived in Marion County with Illinois felony records. Manson Jr., 35, was convicted of aggravated criminal sexual abuse of a 13-year-old girl in McHenry County and sentenced to 20 years. His father served the same sentence for threatening the sheriff’s detective who investigated that case.
Manson Jr. registered in Arkansas as a Level II sex offender. Neighbors on County Road 8054 spent about 18 months reporting the family to the sheriff’s office and the Arkansas Department of Human Services. Sheriff Gregg Alexander kept a handwritten log of 16 calls for service from a single neighbor between November 2024 and June 2025.
An Illinois resident who had lived across the street from the family emailed Alexander directly in September 2025 to warn him about Manson Jr.’s history. The warning went largely unheeded.
In December 2025, Manson Jr. was charged with raping his 10-year-old stepdaughter at the County Road 8054 home. Case 45CR-25-118 charges rape, a Class Y felony, and sexual assault in the second degree, both with a habitual offender enhancement. He was also charged with kidnapping, terroristic threatening and possession of a firearm by a felon after deputies said he threatened the child and an adult woman with a shotgun.
He posted a combined $350,000 bond and was released on an ankle monitor. His wife, Amber Manson, left the property after the December incident.
Within three months of his release, prosecutors allege, a second woman was raped at the same address. She walked into the sheriff’s office on March 7 and reported the assault after escaping to a neighbor’s home. Criminal Investigator Jarrod D. Poley signed a probable cause affidavit five days later.
All three Mansons were arrested. Dezarae Manson, 19, faces rape, sexual assault in the second degree and coercion, with bond set at $25,000. Court filings and sources have described her as Manson Jr.’s stepdaughter and girlfriend.
The three were charged in the same alleged rape but were never tried together, and each has a separate case number. Clifford entered all three cases as their attorney.
The three pleaded not guilty in April. Clifford told the court that discovery would show a strong chance of acquittal.
The child rape case was set for trial July 13. Clifford asked to move it out of Marion County, citing pretrial publicity. Circuit Judge Andrew S. Bailey denied the venue request and instead allowed extra time to question jurors.
The trial never went forward. Bailey continued it the same day, and a docket entry two days later canceled the jury trial. No new trial date has been set.
What comes next
Bailey ordered Manson Jr. and his counsel to appear for a status hearing at 9:30 a.m. Aug. 18 at the Marion County Courthouse. The order covers six case numbers: 45CR-25-82, 45CR-25-103, 45CR-25-111, 45CR-25-117, 45CR-25-118 and 45CR-26-12.
As of Monday, no attorney was listed to appear with him.
