Task: Text Completion
Input (English): of counsel issues. The Sixth Amendment has been interpreted as guaranteeing the right to effective assistance of counsel. McMann v. Richardson, supra. In following this mandate, the' majority of the circuits hold that the Sixth Amendment requires that assistance of counsel be measured against a standard higher than “sham and mockery” and rise to the level of reasonably competent assistance of counsel. The move toward this more demanding standard has been slowly evolving. Indeed it is our belief that even though courts in this circuit have articulated the “sham and mockery” test, they have been in fact applying the more stringent “reasonably competent” test, and that formal adoption of this standard represents a change in name. See Beckett v. Hudspeth, 131 F.2d 195 (10th Cir. 1942) (<HOLDING>). It seems appropriate, nevertheless, to 
 Holding statements: (A) holding that the sixth amendment right to counsel embodies the right to effective assistance of counsel (B) recognizing that the sixth amendment guarantees a defendant the right to counsel and the right to waive counsel (C) recognizing that a criminal defendants right to counsel is the right to the effective assistance of counsel (D) holding the sixth amendment guarantees the effective assistance of counsel at all stages of a criminal proceeding including during the plea process (E) recognizing that the sixth amendment guarantees the right to effective assistance of counsel
Output (English): (E)