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What is the significance of the Supreme Court case MASSARO v. UNITED STATES?

The Massaro case addressed a crucial issue in the U.S.

criminal justice system - whether a defendant must raise an ineffective-assistance-of-counsel claim on direct appeal or can raise it for the first time in a collateral proceeding.

The case involved the late discovery of a bullet that prosecutors claimed was evidence against the defendant, Joseph Massaro, but which they failed to disclose to the defense in a timely manner.

Massaro was convicted of federal racketeering charges, including murder in aid of racketeering, related to the shooting death of Joseph Fiorito.

The U.S.

Court of Appeals for the Second Circuit initially upheld Massaro's conviction, even though his trial counsel was allegedly ineffective for failing to challenge the late disclosure of the bullet evidence.

The Supreme Court's ruling in Massaro v.

United States established that defendants are not required to raise ineffective-assistance claims on direct appeal and can instead bring them in a collateral proceeding under 28 U.S.C.

§ 2255.

The Court reasoned that requiring defendants to raise such claims on direct appeal would often be impractical, as the trial record may not be sufficient to evaluate the quality of counsel's performance.

Massaro's case highlighted the importance of the Sixth Amendment's guarantee of effective assistance of counsel, which the Supreme Court has long recognized as essential to a fair trial.

The decision in Massaro v.

United States was unanimous, with all nine justices agreeing that the defendant should be allowed to bring his ineffective-assistance claim in a collateral proceeding.

The case built upon the Court's earlier decision in Strickland v.

Washington, which established the two-part test for evaluating claims of ineffective assistance of counsel.

Massaro's case demonstrated the challenges defendants can face in proving ineffective assistance of counsel, as the trial record may not always reveal the full extent of counsel's deficiencies.

The ruling in Massaro v.

United States has been widely praised by legal scholars and criminal defense attorneys as protecting the rights of defendants and ensuring the integrity of the criminal justice system.

The case has had a lasting impact, as it continues to be cited by courts when addressing the appropriate forum for ineffective-assistance-of-counsel claims.

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