Few challenges to a judicial determination are as disruptive as a criminal defendant’s allegation of ineffective assistance of counsel. Discovering the truth behind such an allegation is extremely difficult, owing both to the distorting effect of hindsight and the near impossibility of discovering the full extent of any damage caused by defense counsel’s alleged errors. This Note examines the genesis of the confusion concerning the current standard for granting post-conviction relief due to ineffective assistance of counsel and the Missouri Supreme Court’s most recent effort to clarify that standard in Deck v. State.

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