Jed S. Rakoff
Forum
Frye and Lafler: Bearers of Mixed Messages
**This Essay is part of a Yale Law Journal Online series called "Summary Judgment," featuring short commentaries on recent Supreme Court cases.**
In two five-to-four decisions rendered on March 21, 2012—Missouri v. Frye and Lafler v. Cooper—the Supreme Court extended the Sixth Amendment right to ef…