Despite the advent of the limited practice of law by law students as early as 1957, a California Court of Appeals in 1978 became the first court to examine the sixth amendment status of student representation in state criminal prosecutions. In People v. Perez, a California appellate court concluded that a lawyer-supervised law student, certified for limited practice by the California Student Practice Rules, is per se ineffective counsel in felony trials. Ostensibly to protect the defendant's right to effective counsel, Perez struck down the student practice rules without considering the proper function of certification in sixth amendment analysis. Moreover, the court misapplied sixth amendment principles in concluding that the Constitution does not allow student representation in felony trials, irrespective of the presence of a supervising attorney at trial.
Catherine Walker, Status of Student Practice Rules People v. Perez—An Initial Look at the Sixth Amendment, 2 SEATTLE U. L. REV. 420 (1979).