argument that Plakio represented only an extension of the law as announced in Arnold and Norris is unavailing. The dissent in Plakio argued that the court should look only at the maximum possible sentence allowed for any defendant convicted of the particular crime — not simply the defendant before the court. 433 F.3d at 698 (O’Brien, J., dissenting). Judge O’Brien noted that this approach, not the court’s approach, would be “a logical extension” of the precedents in Norris and Arnold. Id. Though Lackey argues that Plakio did not change our circuit’s law on the contested point, Judge O’Brien was certainly convinced otherwise. In light of this, we cannot fault trial counsel for failing to predict the course that Plakio would chart. Bullock v. Carver, 297 F.3d 1036, 1052 (10th Cir.2002) (<HOLDING>) (quotation omitted). III. CONCLUSION We grant
recognizing constitutional right to effective counsel holding that when a representation was that the insured had what coverage it needed  such a statement does not rise to the level of specificity required to be a representation of liquor liability coverage recognizing that a debtors promise related to a future action is not a representation concerning a current or past fact and therefore is not a false representation or false pretense under  523a2a holding that the defendant did not validly waive his right to conflictfree representation where the district court inadequately advised the defendant of the risks of multiple representation holding that clairvoyance is not a required attribute of effective representation