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In Rompilla v. Beard, decided June 20, 2005, the United States Supreme Court reversed the conviction of a defendant sentenced to death because defense counsel failed to conduct an adequate investigation in preparation for the defendant’s capital sentencing hearing. In support of its decision, the Court relied upon Standard 4-4.1 of the American Bar Association’s Defense Function Standards (2d ed., 1982), noting that the standards are “guides to determining what is reasonable.” Professor Lefstein served as the reporter for the second edition of the ABA’s Defense Function Standards, and he also chaired the ABA Task Force that developed the third edition of these standards, which were approved by the ABA in 1991. The Supreme Court in Rompilla cited the second edition of the standards since the capital case was tried while the second edition’s recommendations constituted ABA policy. “Actually, the decision was far more important than just the reversal of a single conviction in a capital case,” Lefstein says. “It sends a very strong and powerful message to defense lawyers in this country that the Supreme Court will no longer tolerate inadequate factual investigations, especially in death penalty cases.”