id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
cjrl-3412	Rogers, Shane	Providing Broader Sixth Amendment Protections: We Can Afford to Give Indigent Defendants More	2019	46	.pdf	application/pdf	17127	698	52	Therefore, there should be Sixth Amendment ineffective assistance of counsel relief from pre-indictment plea deals. [Vol. 9:2 Amendment guarantees a criminal defendant the right to counsel, but it also provides a defendant the right to effective assistance of counsel.3 Right to counsel law, however, seems to preclude providing relief for ineffective assistance of counsel received during pre-indictment plea negotiations.4 The Supreme Court has not directly ruled on the issue,5 but circuit courts have held that the right to counsel must attach before a defendant has the right to effective assistance of counsel and therefore have not entertained the merits of whether counsel can be ineffective pre-indictment.6 This is unjust.	cache/cjrl-3412.pdf	txt/cjrl-3412.txt