Duquesne Law Review


Stephanos Bibas


I am delighted that Professor Wes Oliver and the Duquesne University School of Law are hosting this timely and important symposium on plea-bargaining after Lafler and Frye and this panel on what it takes to make defense counsel effective negotiators. Those decisions have provoked a long-overdue conversation about what kind of defense lawyering is effective and constitutionally required in a world of guilty pleas. Though the Court recognized decades ago, in Hill v. Lockhart, that ineffective assistance could taint guilty pleas, it is only now working through what that principle must mean and how to implement it in practice.

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