Courts interpreting effective representation should look at authoritative statements of what counsel ought to do (such as the ABA Guidelines), rather than what may be customary among practitioners whose clients frequently end up on death row. Most cases avoid death sentences, and the standards are established by practitioners who represent capital clients successfully.
Stetler, Russell and Wendel, W. Bradley
"The ABA Guidelines and the Norms of Capital Defense Representation,"
Hofstra Law Review: Vol. 41
, Article 7.
Available at: https://scholarlycommons.law.hofstra.edu/hlr/vol41/iss3/7