Which of the Following Is Not a Reason the Court

Which of the following is not a reason the Court, in Strickland v. Washington, refused to adopt performance guidelines for evaluating counsel in capital cases?

A) the Court assumed that any attorney who graduated from a reputable law school and had passed the bar exam was competent to represent capital defendants
B) the purpose of the effective assistance guarantee was not to improve the quality of legal representation
C) the Court concluded that no particular set of detailed rules for counsel's conduct could satisfactorily take account of the variety of circumstances faced by defense counsel or the range of legitimate decisions regarding how best to represent a criminal defendant
D) the Court was concerned that the adoption of specific standards would encourage ineffectiveness claims, which would discourage many attorneys from representing defendants in capital cases
E) all of the above were reasons