The U.S. Supreme Court's Failure to Fix Plea Bargaining: The Impact of Lafler and Frye

In the 2012 companion cases of Lafler v. Cooper and Missouri v. Frye, the United States Supreme Court held that there is a right to effective assistance of counsel during plea bargaining, even when a defendant later loses at trial. Legal commentators suggested the cases were “the single greatest revolution in the criminal justice process since Gideon v. Wainwright,” that the cases will have a “significant effect,” and that they were “the term’s decisions with the greatest everyday impact on the criminal justice system.” But, will