The court used the case as an opportunity to lay out in detail how defense lawyers are to proceed in the face of anticipated perjury. First, the lawyer may not resort to the narrative technique unless the defendant expressly tells the lawyer that he intends to lie. Then, the lawyer must attempt to talk the defendant out of lying. Failing that, the lawyer must also tell the client that, if the client insists that he will lie, then the lawyer will allow the defendant to testify only in narrative form and the consequences of doing so. The lawyer must then inform the court and the prosecution of the defendant's intent. Only then may the lawyer resort to narrative testimony.

In another decision, U.S. v. Miggett, the Fourth Circuit reversed a conviction for counsel's refusal to put a client on the stand when the client insisted his story was true.

"Far-fetched as Midgett's story might have sounded to a jury, it was not his lawyer's place in these circumstances to decide that Midgett was lying and to declare this opinion to the court." But the court ultimately reversed not on ineffective assistance grounds, but because the trial judge declined to permit counsel to withdraw and gave Midgett a choice: Continue with his counsel (and thus not testify), or represent himself (and thus be able to tell his story to the jury as he wished). An unconstitutional Hobson's choice, the court found.