This article contends that Missouri v. Frye and Lafler v. Cooper, holding that defendants have a right to an effective criminal negotiator, are landmark
decisions that should be applied retroactively. The article argues that the right to effective counsel is a fundamental right that should be applied retroactively. The article also argues that the right to effective counsel is a right that is not subject to a harmless error analysis. The article concludes that the right to effective counsel is a right that