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16 Welch, 148 F. 2d 667, 670 (CADC 1945); see Bottiglio v. United States, 431 F. 2d 930, 931 (CA1 1970) (per curiam); Williams v. Beto, 354 F. 2d 698, 704 (CA5 1965); Frand v. United States, 301 F. 2d 102, 103 (CA10 1962); O’Malley v. United States, 285 F. 2d 733, 734 (CA6 1961); Snead v. Smyth, 273 F. 2d 838, 842 (CA4 1959); Cofield v. United States, 263 F. 2d 686, 689 (CA9), vacated on other grounds, 360 U. S. 472 (1959); Johnston v. United States, 254 F. 2d 239, 240 (CA8 1958); ''United States ex rel. Feeley v. Ragen, 166 F. 2d 976, 980–981 (CA7 1948); United States v. Wight'', 176 F. 2d 376, 379 (CA2 1949).

Beginning in 1970, the Courts of Appeals moved from the “farce and mockery” standard to a “reasonable competence” standard. See Trapnell v. United States, 725 F. 2d 149, 151–152 (CA2 1983) (collecting cases). That same year, this Court similarly held that defendants are “entitled to the effective assistance of competent counsel,” defined as receipt of legal advice that is “within the range of competence demanded of attorneys in criminal cases.” McMann v. Richardson, 397 U. S. 759, 771 (1970).

Then, in Strickland, the Court crafted the current standard for evaluating claims of ineffective assistance of counsel. Without discussing the original meaning of the Sixth Amendment, the Court stated that “[t]he Sixth Amendment recognizes the right to the assistance of counsel because it envisions counsel’s playing a role that is critical to the ability of the adversarial system to produce just results.” 466 U. S., at 685. The Court thus held that, to succeed on an ineffective-assistance claim, the defendant must show (1) “that counsel’s representation fell below an objective standard of reasonableness” and (2) “that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Id., at 688, 694. The Court applies this standard in most situations, but, as it does today, it has also created an increasing number of per se rules in