The Supreme Court recently held in Williams v. Taylor that absence of mitigation evidence in a capital trial can establish a claim for ineffective assistance of counsel. Following the holding in Williams, this Note argues that appellate courts should automatically overturn death sentences in which the defense attorney does not present some threshold amount of mitigation evidence.  The Note goes on to examine the Strickland v. Washington test for finding ineffective assistance of counsel and posits that the Strickland test is unworkable in requiring a balancing of the incommensurate values of harm and mitigation.  Therefore, appellate courts should apply a threshold analysis when examining death sentence cases.