Whether the threat of a civil action by a criminal defendant against his attorney is a per se denial of the right to the effective of counsel guaranteed by the Sixth Amendment of the United States Constitution, and thus does not require a defendant to make a showing of the attorney's deficient performance or prejudice in order to vacate his conviction.

Whether the threat of a civil action by a criminal defendant against his attorney is a per se denial of the right to effective counsel guaranteed by the Sixth Amendment