This chapter returns to the issue of the vanishing trial. In 2005, the Supreme Court decided in United States v. Booker that the federal sentencing guidelines were only “advisory” so that, while judges were free to take them into account, they could also make their own decisions under the traditional goals of sentencing: retribution, rehabilitation, deterrence, and incapacitation. The expectation was that this would increase trials because defendants could go to trial and, if convicted, still have a chance to argue for a lighter sentence than the guidelines “advised.” Instead, the trial rate plummeted even more when judges were freed from the guidelines. This chapter explains why trials declined by contrasting two different advocacy styles: extreme adversarialism and muted adversarialism. To show extreme adversarialism, this chapter revisits the OJ Simpson trial and contrasts this style of advocacy with the muted advocacy in the England trial system. The chapter explains how sentencing in the U.S. has traditionally demanded muted advocacy; it is not a straightforward adversary hearing, nor should it be. Once advocacy returned to sentencing in federal courts, it is not surprising that defense lawyers much preferred to advocate for their clients at sentencing, not at trials. The frequency of downward sentencing departures suggests they are making the right choice.