Regardless of the strategy chosen, a survey of many cases discloses that the strategy may be questioned later in proceedings assailing the choice. The largest single area of complaint has been trial counsel's failure to call certain witnesses. Defendants have also accused lawyers of poor cross-examinations and have made other charges relating to evidentiary matters. In a small but significant number of recent cases, convictions were reversed for mistakes of strategy or tactics. In cases not reversed, the claims were either ludicrous or the challenged actions were in line with a plausible defense theory. Analyzing the many opinions indicates that the following factors influenced reversals of convictions: the extent to which error can be related to failures of inadequate preparation, investigation, or forethought; whether the error was arguably in pursuit of any reasonable defense strategy; the likelihood that the error affected the case outcome; the strength of the prosecution's case; judicial fears relating to securing an unbiased jury; and others. To rule on future claims, the courts should rely on a four-question analysis, asking whether counsel developed a plausible and legally correct theory of the case, whether counsel's strategy was adequately prepared and investigated, whether counsel's tactics were related to the strategy, and whether the strategy and tactics used would appear sound to a reasonably competent criminal attorney facing similar problems without benefit of hindsight. A total of 281 footnotes are provided.