did not present evidence of Cone's drug use as mitigating evidence. Cone's attorney also waived his final argument so that the prosecutors would not have an opportunity for a rebuttal argument. The trial court ultimately sentenced Cone to death, and on appeal, the Tennessee Supreme Court affirmed Cone's convictions and sentence. Petitions for postconviction relief Cone later filed a petition for postconviction relief, in which he argued that his attorney provided ineffective assistance of counsel by waiving his closing argument and by failing to present mitigating evidence during the sentencing phase of his trial. After conducting a hearing on Cone's petition, a Tennessee state court rejected Cone's contentions, and the Tennessee Court of Criminal Appeals affirmed the lower court's ruling. The Tennessee Court of Criminal Appeals concluded that Cone's attorney acted within an acceptable range of competency and that Cone "received the death penalty based on the law and facts, not on the shortcomings of counsel." Both the Tennessee Supreme Court and the United States Supreme Court declined to consider further appeals. In 1997, Cone filed a petition for a writ of habeas corpus in federal court. In his petition, he alleged that his attorney provided ineffective assistance of counsel during the sentencing phase of his trial, but the federal district court denied his petition. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court's ruling with respect to Cone's conviction, but it revered the district court's ruling with respect to Cone's sentence. The Sixth Circuit held that Cone "suffered a Sixth Amendment violation for which prejudice should be presumed" because his attorney's failure to ask for mercy "did not subject the State's call for the death penalty to meaningful adversarial testing." Additionally, the Sixth Circuit held that the Tennessee Court of Criminal Appeals decision constituted "an unreasonable application of the clearly established law". In 2001, the United States Supreme Court granted certiorari. Opinion of the Court In an opinion written by Chief Justice William Rehnquist, the Supreme Court reversed the Sixth Circuit's ruling and remanded the case to the Sixth Circuit for further proceedings. Chief Justice Rehnquist stated that the Tennessee state court correctly identified Strickland v. Washington'''s two-part test as the proper legal standard for effective assistance of counsel when it rejected Cone's petition for postconviction relief. Under this standard, Cone would need to demonstrate that his attorney's "representation fell below an