ABSTRACT
The US Supreme Court has long acknowledged that the Sixth Amendment right to an attorney in criminal cases, which the landmark decision in Gideon v. Wain-wright, 372 US 335, afforded to state as well as federal defendants, subsumes the right to effective assistance, whether the attorney be hired or assigned by the court. It is important to distinguish between two lines of precedent in this area. The first deals with situations in which government interferes with counsel in some respect, such as when a judge forbids attorney-client consultation during an overnight recess at trial or prevents the attorney from making a closing argument. The second group of decisions involves claimed ineffective assistance of counsel in the absence of governmental obstruction; a subset of these decisions concern attorneys laboring under a conflict of interest. The Court has been much less indulgent with defendants who attack their lawyers, not the state-and has made relief much harder to obtain.
