In Tyson v Superintendent Houtzdale SCI, the 3rd Circuit held that a criminal defendant’s trial counsel rendered ineffective assistance by failing to object to the trial court’s jury instruction. The trial court incorrectly instructed the jury that an accomplice to first-degree murder must only act to promote or facilitate the commission of a crime to be convicted, and failed to instruct the jury that the accomplice must still have a specific intent to kill. The instruction was a violation of the defendant’s Due Process rights, and counsel was ineffective for failing to object to it.