Whether sentencing counsel's failure to make any meaningful objections to the Presentence Investigation Report, failure to argue for any particular sentence, and minimal advocacy at sentencing—consisting only of a statement expressing confidence in the court—constitutes the kind of failure to "subject the prosecution's case to meaningful adversary testing" that "makes the adversary process itself presumptively unreliable" under United States v. Cronic, 466 U.S. 648 (1984), thereby entitling a defendant to relief without a separate showing of prejudice under the Sixth Amendment.

Whether minimal sentencing advocacy that fails to meaningfully challenge the prosecution's sentencing recommendation constitutes a complete denial of counsel under Cronic