The article examines the implications of the Second Circuit's analysis in Boria v. Keane for courts' evaluations of effective assistance of counsel and for clinical legal scholarship's formulations of client-centered counseling. In addition, the article: (1) describes the development of the effective assistance of counsel doctrine and its relation to client counseling; (2) analyzes the concept of client-centered counseling and its implications for an attorney's role in advising clients, concentrating on clinical legal scholars' attempts to apply client-centered counseling to clients in criminal cases; (3) evaluates in greater detail the history and holding of Boria; and (4) argues that the final, published holding in Boria did not go far enough to ensure that defense attorneys provide the effective assistance of counsel. Notes