This Comment reviews the historical development of the right to effective assistance of counsel for criminal defendants as defined by the Supreme Court, and discusses the various standards applied by lower federal courts. This Comment next examines United States v. Decoster, which provides the most comprehensive judicial analysis of the right to effective assistance of counsel at this juncture in time. The standards applied by the New York State courts are also analyzed. Finally, the author recommends uniform guidelines for evaluating claims of ineffective assistance of counsel.
The Effective Assistance of Counsel: Chance or Guarantee?,
11 Fordham Urb. L.J. 85
Available at: http://ir.lawnet.fordham.edu/ulj/vol11/iss1/3