United States v. Cronic
United States Supreme Court
466 U.S. 648 (1984)
Cronic (defendant) was indicted on mail fraud charges after a four-and-a-half-year government investigation into a check-kiting scheme; shortly before trial his attorney withdrew, and the court appointed a young real estate lawyer who had only 25 days to prepare. After Cronic's co-defendants agreed to testify for the prosecution, Cronic was convicted on 11 of 13 counts. The court of appeals reversed, reasoning that circumstances like the short preparation time, the attorney's inexperience, and the case's complexity were enough to presume ineffective assistance without identifying any specific error by counsel, and the government sought Supreme Court review.
Whether a defendant claiming a Sixth Amendment violation for ineffective assistance of counsel must point to specific errors by counsel, or may instead rely on a presumption of ineffectiveness based on the surrounding circumstances alone.