The Yale Law Journal

Jed S. Rakoff


Frye and Lafler: Bearers of Mixed Messages

Jed S. Rakoff

**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…