The most definitive standard for assessing the effectiveness of counsel yet articulated came from the Court of Appeals for the District of Columbia in United States v. Decoster (1973, 1979) in deciding that 'a defendant is entitled to the reasonably competent assistance of an attorney acting as his diligent, conscientious advocate.' The court went on to list several specific duties a criminal defense attorney is obligated to perform. Studies have shown that defendants represented by public defenders tend to view the effectiveness of counsel less favorably than those represented by lawyers. Texas and Baltimore inmate studies reported in this paper confirm this finding. Studies have also shown, however, that there are no substantive differences between the two types of counsel in terms of case outcomes. Alpert (1981) has suggested that criminal defense strategies are on a continuum that begins with the attorney relying solely on what the defendant says, building the case accordingly, moving then to the attorney who is innovative and resourceful in devising a defense, and finally to the extreme of manufacturing a defense based on manipulation and distortion. Policy recommendations include (1) establishing minimum standards for legal defense advocacy, (2) court monitoring of defense performance at various processing stages, (3) increased funding for defense advocacy, (4) law school curricular reform, (5) better bar association enforcement of ethical and competency codes, and (6) ongoing education programs on the law and legal services. Six notes and 33 references are provided.