The following excerpt is from Santana v. Foulk, Case No. 1:13-cv-02034 MJS (HC) (E.D. Cal. 2015):
The Sixth Amendment entitles a criminal defendant to an attorney who "'function[s] in the active role of an advocate.'" Plumlee v. Masto, 512 F.3d 1204, 1211
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