There was an important reason why these cases did not qualify as "ineffective assistance of counsel." The prisoners who brought the cases to the Supreme Court could not prove the second piece of the "Strickland test." They could not prove that if they had different lawyers, their trials would have turned out differently. There was so much evidence against them, and they were so obviously guilty, that the appeals courts decided having a different lawyer would not have made any difference. No lawyer could have saved these cases, the state courts basically said.