Constitutional Law——When Controversial Trial Tactics Satisfy a Defendant’’s Right to the Effective Assistance of Counsel——Bell v. Cone, 535 U.S. 685 (2002)

The Sixth Amendment to the United States Constitution guarantees all criminal defendants the right to counsel.  Due to the confusion that existed as to whether the right to “”counsel”” meant the right to ““effective counsel,”” the United States Supreme Court established guidelines for the lower courts to follow.  In Bell v. Cone, the Court considered whether an attorney who waived closing arguments and offered no mitigating evidence, in a capital sentencing hearing, met the Court’’s definition of ineffective counsel.  The Court concluded that it was not unreasonable for the state appeals court to interpret the attorney’’s conduct as strategic, and therefore effective. . . .