In Julian v. Bartley (7th Cir. 2007), 495 F.3d 487the Seventh Circuit held that Julian, who was misadvised by his counsel that he "couldn't get anything more than 30" if he pleaded guilty to robbery when the defendant faced 60 years based on his prior armed robbery conviction, was denied the effective assistance of counsel guaranteed him by the Sixth Amendment. The court noted that although a mistaken prediction by counsel is not sufficient to show deficient performance, in some cases it may be such a gross mischaracterization that it provides a "strong indication of constitutionally deficient performance," citing United States v. Martinez (7th Cir. 1999), 169 F.3d 1049.