The American Bar Association's standards provided some support, but more recent cases illustrate the Court's struggle to establish to establish clear guidelines for lower courts to follow when deciding whether defense counsel's performance is considered unconstitutional within the meaning of Strickland.

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The American Bar Association's standards have historically provided guidance on what constitutes effective legal representation, but the Supreme Court has indeed faced challenges in setting clear, consistent standards for lower courts to apply under the Strickland v. Washington framework when evaluating claims of ineffective assistance of counsel.

The American Bar Association's Standards Provided Some Support, but More