There are a growing number of critics of the Strickland standard for determining effective assistance of counsel.

The critics argue that the standard hides from judicial review substandard representation. Most opinions that affirm Strickland claims of ineffective assistance of counsel are not as blunt as State v. Cahill, 2013-Ohio-3753 (Ohio Ct. App. Aug. 30, 2013):

For all of Cahill’s protestations to the contrary, this was an open-and-shut case, competently presented by the prosecutor. The finest criminal defense lawyer in the land cannot work a miracle. Cahill was not constitutionally entitled to a victorious defense counsel, he was merely entitled to an effective defense counsel; and he had one.