RAKER, J.
In this post-conviction appeal, petitioner asks this Court to decide whether the presumption of prejudice set out in United States v. Cronic, 466 U.S. 648, 104 S.Ct. 2039, 80 L.Ed.2d 657 (1984), applies to his claim of ineffective assistance of counsel under the Sixth Amendment to the United States Constitution. We shall answer this question in the negative and hold that in order to establish ineffective assistance of counsel, petitioner must satisfy the two prong test set out in Strickland v. Washington, 466 U.S. 668, 104 S.Ct. 2052, 80 L.Ed.2d 674 (1984): that counsel’s performance was deficient and that the deficient performance prejudiced the defendant.
I.
Petitioner, Le’bon Walker, Patricia Lee (Walker’s wife), and Anna L. Hall (Lee’s mother), were indicted by the Grand Jury for Montgomery County with conspiracy to commit theft and nine counts of theft, in violation of Md.Code (1957, 1992 [238]*238Repl.Vol., 1993 Cum.Supp.) Art. 27, § 342.1 Trial was scheduled for January 18, 1993, and both Walker and his wife were notified of the trial date and location. Walker and his wife were released on bond approximately eight days before trial; they absconded from the jurisdiction. Based upon information provided to the Circuit Court by the Pre-Trial Services Unit, the Circuit Court issued bench warrants for Walker and his wife. Neither defendant was apprehended before the trial date.
Walker’s case was consolidated for trial with the eases of his wife, Patricia Lee, and Lee’s mother, Anna Hall. On January 18, 1993, the cases were called for trial before the Circuit Court; Walker and Lee failed to appear. Anna Hall was present and was represented by counsel. Following a hearing concerning the absence of Walker and Lee, and over defense counsel’s objection, the trial court proceeded in absentia. After the jury was sworn, defense counsel again argued to the trial court that his clients could not get a fair trial in absentia and said that he believed that they would not want him to participate in the proceedings. The following colloquy took place on January 19, 1993:
“[DEFENSE COUNSEL]: After careful and considerable thought overnight, I believe that the defendants cannot get a fair and impartial trial in this case by being tried in absentia. It is clear from our jurisprudence that trials in absentia are not the rule in this country, it violates the common law; it violates the Confrontation Clause of the Sixth Amendment to the Constitution of the United States, and it violates Article 21 of the Maryland Declaration of Rights. As the Supreme Court indicated in no uncertain terms in the Crosby [v. United States, 506 U.S. 255, 113 S.Ct. 748, 122 L.Ed.2d 25 (1993)] case, which we reviewed yesterday, the Supreme Court does not sanction trials in absentia. Your Honor recalled, the fact pattern is, I would [239]*239say identical to the case here and the Court unanimously ruled under [Federal Criminal! Rule [of Procedure] 43 that defendants could not be tried in absentia. The Maryland Rule and the Federal Rule are both there for the protection of the defendant, to use as a shield, as brought out yesterday, and I believe because of that and without the defendants’ presence here, I cannot effectively represent my clients, and to proceed on their behalf in any way would be a sham. Moreover, in reviewing my conversations with my clients, and their view of the past history of this case, I unhesitatingly believe that they would not want me in any way to participate any further in this trial. Therefore, I will not validate these proceedings by my participation and I respectfully ask this court to excuse my appearance from this case. If the court orders me to remain here, I will do so, but I shall not in any way participate further in the trial.
[THE COURT]: May I ask you this, [defense counsel], do you believe as a strategy of defense of your clients and in their best interests, that it would be appropriate for you not to actively participate in the examination of any witnesses? Is that correct?
[DEFENSE COUNSEL]: I do believe that.
[THE COURT]: Okay. Are you expressing that because you think that is the best way to zealously safeguard the interests of your clients and protect them in this criminal proceeding?
[DEFENSE COUNSEL]: I believe that I could not—by participating in the trial, by cross-examining witnesses, without having the benefit of my clients next to me to talk to and obtain information from them, that it would be ineffective assistance of counsel.
[THE COURT]: Well, recognizing that certainly the ideal situation would be for them to be here with you and able to give you immediate feedback, have you made a decision of your trial strategy in protecting their interests, that it is in their best interests for you to take a passive role?
[DEFENSE COUNSEL]: Yes, I have made that decision.
[240]*240[THE COURT]: Okay. So, your motion is to be excused from trial?
[DEFENSE COUNSEL]: That would be my motion, that I be excused at this time.
[THE COURT]: Okay. Well, for the reasons I believe that I stated upon the record yesterday, and in the ruling that I make, I will deny the motion for you to be excused from the trial, and I believe as we discussed, you are required to participate in their defense since the trial against them is proceeding, and I believe you have stated upon the record that you propose to follow what you believe to be the rules of professional responsibility that apply to you and the manner which you have chosen to safeguard their rights.”
Following the Circuit Court’s denial of defense counsel’s request to be excused, the Court proceeded with the jury trial. Defense counsel waived opening statement, made no trial motions or objections, did not call any witnesses, and did not cross-examine any of the State’s witnesses.2 During a discussion with the Court regarding jury instructions, defense counsel raised the possibility of arguing jury nullification in his closing argument based on his opinion that it was impossible for Walker and Lee to get a fair trial in absentia:
“[DEFENSE COUNSEL]: Your Honor, I was thinking about summation and telling the jury that they should acquit the defendants because this whole proceeding is unconstitutional.
[THE COURT]: Well, I won’t permit you to make that argument to the jury. That is not argument, that is jury nullification. That is an improper argument to make for the jury. If your position is ultimately sustained, it would be on the appellate level, not by the jury.
[241]*241[DEFENSE COUNSEL]: I have been trying to get some support for that, and I will try to find some additional research.”
The court did not allow counsel to argue that the trial in absentia was unconstitutional, and counsel renewed his request at the end of the discussion:
“[DEFENSE COUNSEL]: Just for the record, I just want to take exception to the Court’s ruling that I cannot argue jury nullification as the Court determined it this morning.
[THE COURT]: Okay. And so that this is clearly on the record, what you had proposed is to argue to the jury that proceeding against [Walker and Lee] in their absence is unconstitutional.
[DEFENSE COUNSEL]: That is correct.
[THE COURT]: And since I think that is contrary to the law, and I give [the jury] binding instructions on the law, I think 1 have no choice but to [instruct] you that you can’t argue that. Thank you.”
The jury found Walker and Lee guilty on all counts alleged in the indictment.3 Nine months later, Walker and Lee were apprehended in Zambia, returned to the United States, and sentenced to a term of incarceration of twenty-four years in the Division of Correction with credit for 390 days for time served. Walker noted a timely appeal to the Court of Special Appeals, and this Court granted certiorari on its own initiative to consider whether a trial court may try a defendant in absentia consistent with a defendant’s common law right to be present at trial and a Sixth Amendment right to confrontation. Walker v. State, 338 Md. 253, 658 A.2d 239 (1995) (“Walker I ”). This Court affirmed, holding that the trial court did not err in proceeding to trial in the defendant’s absence, leaving [242]*242for another day the question of effective assistance of counsel. Id. at 261-62, 658 A.2d at 243.
Walker filed a petition for post-conviction relief in the Circuit Court for Montgomery County pursuant to the Uniform Postconviction Procedure Act, Md.Code (2001, 2005 Cum. Supp.) Criminal Procedure Article, § 7-102, alleging, inter alia, that defense counsel’s trial strategy was merely to do nothing at all, which amounts to a “total breakdown” in the adversarial process, thereby presumptively prejudicing him under United States v. Cronic, 466 U.S. 648, 104 S.Ct. 2039, 80 L.Ed.2d 657 (1984). The Circuit Court denied relief on all grounds, ruling that Walker was not prejudiced by his counsel’s performance. In rejecting Walker’s presumption of prejudice argument under Cronic, the post-conviction Court stated as follows:
“The first ground that counsel is seeking, Mr. Walker, is seeking, to set aside the verdict in this case and to assign a new trial to Mr. Walker is the application of the United States v. Cronic decision. That’s when the decision of counsel to refuse to participate in the trial in this case without the consent of client’s counsel, is a failure to subject the prosecution’s case to meaningful adversarial testing. That there is this presumption of unreliability. I have to say that I agree with what [United States v. Sanchez, 790 F.2d 245 (2d Cir.), cert. denied, 479 U.S. 989, 107 S.Ct. 584, 93 L.Ed.2d 587 (1986)] says. I find that here, Mr. Walker’s own obstructive conduct precluded his attorney from pursuing an intelligent [and] active defense. Therefore, the concerns of Cronic are not invoked. Therefore, the general test of effectiveness of counsel applies under Strickland. I would also point out that I’ve listened to [defense counsel’s] testimony. I’ve reviewed the record and [defense counsel’s] testimony. Although, I understand what you are saying, that there is nothing that reflects the actual consent, or direction or instruction by Mr. Walker from [defense counsel] not to participate, but he did have voluminous discovery, six months of pre-trial preparation, [and] consultation with his client. It was [defense counsel’s] perception, [243]*243based upon his discussions with Mr. Walker, that he would not have wanted [defense counsel] to participate in the trial. In addition, the conduct of the trial [c]ourt in this regard is, again, appropriate to the record. That is Judge Harrington meticulously went over ... [defense counsel’s] decision. [Defense counsel had] every opportunity to participate. [Judge Harrington] specifically asked him on the record: do you believe as a strategy of defense of your clients and in their bests interest that it would be appropriate for you not to actively participate in the examination of any witnesses. Is that correct? [Defense counsel] responded, that he did believe that, which is consistent with what he said here on the witness stand.
[H]e believed it was in Mr. Walker’s best interest to not zealously represent Mr. Walker at trial. If I were to set aside the verdict in this case, it would in essence [reward] Mr. Walker for his efforts to sabotage this case and reward him by allowing him to intentionally sabotage his own defense. I agree that, as was said in the Sanchez case, that would ‘defy both the purposes of the Sixth Amendment and common sense.’ ”
Walker noted a timely appeal to the Court of Special Appeals. The intermediate appellate court, in a well-reasoned and thoroughly researched opinion, affirmed, holding that Cronic was inapplicable, that the Circuit Court properly applied the two prong test announced in Strickland, and that Walker’s ineffective assistance of counsel claim was without merit. Walker v. State, 161 Md.App. 253, 868 A.2d 898 (2005). Judge James R. Eyler, writing for the unanimous panel, noted that “[t]he presumption of ineffectiveness is very limited.... and includes only those cases where a defendant is actually or constructively denied counsel altogether, or where the state actively interferes with counsel’s consultation with or representation of a defendant.” Id. at 263, 868 A.2d at 904. The court explained as follows:
“The State did not interfere with counsel’s assistance in any way. [Defense counsel] was fully prepared to try the case. [Petitioner] does not allege that he was prevented by the [244]*244State from consulting with [defense counsel] in any way, or at any time, before, during, or after the trial. [Defense counsel] never testified to any conflict of interest at the post-conviction hearing, nor does [petitioner] argue that a conflict of interest existed. Therefore, this case does not fall into one of the three categories of cases in which the Supreme Court has determined that ineffectiveness or prejudice should be presumed.”
Id. at 268, 868 A.2d at 907.
We granted Walker’s petition for Writ of Certiorari to decide the following question:
“Should prejudice be presumed under United States v. Cronic where trial counsel, by his silence and non-participation at Mr. Walker’s first jury trial, failed to subject the prosecution’s case against Mr. Walker to ‘meaningful adversarial testing’ and denied Mr. Walker his Sixth Amendment right to the effective assistance of counsel?”
Walker v. State, 387 Md. 462, 875 A.2d 767 (2005). We agree with the Court of Special Appeals and shall affirm the denial of petitioner’s request for post-conviction relief.
II.
Petitioner’s sole argument in this appeal is that because his defense counsel did not participate at trial, he was denied effective assistance of counsel under the Sixth Amendment to the United States Constitution and that prejudice should be presumed under United States v. Cronic, 466 U.S. 648, 104 S.Ct. 2039, 80 L.Ed.2d 657 (1984).4 By remaining silent, petitioner contends, defense counsel failed to subject the State’s case to “meaningful adversarial testing” and that trial counsel’s “complete lack of activity on [his] behalf’ had the same effect as if he had no representation in the courtroom at all, and thus, counsel was constructively absent from the proceeding.
[245]*245The State argues that United States v. Cronic does not apply to petitioner’s claim because defense counsel was present throughout the entire trial and that counsel’s limited participation was based on a trial strategy designed to benefit petitioner. Aspects of this strategy included a vehement argument that trial in absentia was unconstitutional and an effort to argue jury nullification on the grounds that the proceeding was unconstitutional. Further, the State contends that trial counsel’s strategy was based upon counsel’s determination of Walker’s wishes and his best interests under the circumstances. In addition to undertaking a legitimate trial strategy, the State contends that trial counsel did not leave the State’s case “untested.” The State notes that trial counsel attended trial and bench conferences, responded to the trial court’s inquiries regarding admission of exhibits, and that the State’s evidence was challenged by counsel for Walker’s co-defendant, Hall.
III.
The Sixth Amendment to the United States Constitution guarantees criminal defendants the right to the assistance of counsel and applies to the states through the Due Process Clause of the Fourteenth Amendment.5 See Gideon v. Wainwright, 372 U.S. 335, 342, 83 S.Ct. 792, 795-96, 9 L.Ed.2d 799 (1963). It is beyond question that the right to counsel is the right to effective assistance of counsel. See Strickland, 466 U.S. at 686, 104 S.Ct. at 2063.
In order to assess the adequacy of counsel’s assistance under the Sixth Amendment, ordinarily we apply the two-part test enunciated by the Supreme Court in Strickland, which requires that a defendant show that counsel’s representation was deficient, ie., that it fell below an objective standard of reasonableness, and that any deficiency in counsel’s [246]*246performance was prejudicial. Id. at 687-88, 104 S.Ct. at 2064; see Florida v. Nixon, 543 U.S. 175, 188-89, 125 S.Ct. 551, 561-62, 160 L.Ed.2d 565 (2004); Bowers v. State, 320 Md. 416, 424-25, 578 A.2d 734, 739 (1990). Prejudice requires a showing that counsel’s errors were so egregious that they deprived the defendant of a fair trial—a trial whose result is reliable. Strickland, 466 U.S. at 687, 104 S.Ct. at 2064. We have framed the test for prejudice under Strickland as requiring the petitioner to show that there is a substantial possibility that the outcome of the proceeding would have been different. Bowers, 320 Md. at 426-27, 578 A.2d at 738.
In deciding a petitioner’s ineffective assistance claim under Strickland, “judicial scrutiny of counsel’s performance must be highly deferential.” Strickland, 466 U.S. at 689, 104 S.Ct. at 2065. When a court decides an ineffective assistance of counsel claim, it must judge the reasonableness of counsel’s conduct on the facts of the particular case, viewed from the time of counsel’s conduct. Id. at 690, 104 S.Ct. at 2066. Further, the court may determine the reasonableness of counsel’s actions in accordance with petitioner’s statements and actions because counsel’s conduct typically is based on “informed strategic choices made by the defendant and on information supplied by the defendant.” Id. at 691, 104 S.Ct. at 2066.
In United States v. Cronic, 466 U.S. 648, 104 S.Ct. 2039, 80 L.Ed.2d 657 (1984), decided the same day as Strickland, the Supreme Court established that certain deficient performances of counsel justified a per se presumption of ineffectiveness under the Sixth Amendment. See id. at 658-659, 104 S.Ct. at 2046. The Court identified three situations implicating the right to counsel that involved circumstances “so likely to prejudice the accused that the cost of litigating their effect in a particular case is unjustified.” Id. at 658, 104 S.Ct. at 2046-47. The first situation was where the accused was completely denied counsel. Id. at 659, 104 S.Ct. at 2047. Complete denial of counsel includes, for example, “when counsel was either totally absent, or prevented from assisting the [247]*247accused during a critical stage of the proceeding.” Id. at 659 n. 25, 104 S.Ct. at 2047 n. 25. The second situation warranting a similar presumption of prejudice was “if counsel entirely fails to subject the prosecution’s case to meaningful adversarial testing” because this results in an “adversary process itself [that is] presumptively unreliable.” Id,. The final situation was in cases similar to Powell v. Alabama, 287 U.S. 45, 53 S.Ct. 55, 77 L.Ed. 158 (1932), where the accused faces circumstances in which it is not likely that any attorney could provide effective assistance.6 Id. at 659-661, 104 S.Ct. at 2047-48. With the exception of these three situations, a defendant must articulate “how specific errors of counsel undermined the reliability of the finding of guilt,” ie., the defendant must prove actual prejudice. See Cronic, 466 U.S. at 659 n. 26, 104 S.Ct. at 2047 n. 26.
Petitioner argues that his claim fits within the second exception identified in Cronic because his trial counsel, although present in the courtroom, failed to subject the State’s case against Walker to “meaningful adversarial testing,” thereby warranting a presumption of prejudice. We disagree. Since Cronic was decided, the Supreme Court has made clear that the Cronic exception to the general rule requiring proof of prejudice based on deficient performance is a very narrow exception, and that for the exception to apply, the “[attorney’s] failure must be complete.” Florida v. Nixon, 543 U.S. 175, [248]*248190, 125 S.Ct. 551, 562, 160 L.Ed.2d 565 (2004) (quoting Bell v. Cone, 535 U.S. 685, 696-697, 122 S.Ct. 1843, 1851, 152 L.Ed.2d 914 (2002)).
In Bell v. Cone, 535 U.S. 685, 122 S.Ct. 1843, 152 L.Ed.2d 914 (2002), a death penalty case before the Court on review of a grant of the writ of habeas corpus by the United States Court of Appeals for the Sixth Circuit, the Court reversed, holding that the Strickland test rather than Cronic exception applied in analyzing petitioner’s claim of ineffective assistance of counsel at his sentencing hearing. Id. Petitioner argued that in the sentencing proceeding, his counsel failed to “mount some case for life” after the State introduced evidence in the sentencing hearing and made closing argument. Id. at 696, 122 S.Ct. at 1851. The Court rejected his argument, explaining the applicability of Cronic as follows:
“When we spoke in Cronic of the possibility of presuming prejudice based on the attorney’s failure to test the prosecutor’s case, we indicated that the attorney’s failure must be complete. We said ‘if counsel entirely fails to subject the prosecution’s case to meaningful adversarial testing.’ Here, respondent’s argument is not that his counsel failed to oppose the prosecution throughout the sentencing proceeding as a whole, but that his counsel failed to do so at specific points. For purposes of distinguishing between the rule of Strickland and that of Cronic, the difference is not of degree but of kind.”
Id. at 696, 122 S.Ct. at 1851 (citations omitted). In analyzing defense counsel’s decision to waive summation, the Court noted that considering the options available to counsel, “[n]either option ... [s]o clearly outweighs the other that it was objectively unreasonable for the Tennessee Court of Appeals to deem counsel’s choice to waive argument a tactical decision about which competent lawyers might disagree.” Id. at 702, 122 S.Ct. at 1854. The Court found that because defense counsel failed to challenge specific aspects of the State’s case rather than entirely fail “to subject the [State’s] ease to meaningful adversarial testing,” Strickland provides the proper framework for reviewing the defendant’s ineffective assis[249]*249tance of counsel claim. See id. at 697-98, 122 S.Ct. at 1851-52.
In Florida v. Nixon, 543 U.S. 175, 125 S.Ct. 551, 160 L.Ed.2d 565 (2004), the Supreme Court again emphasized the limited availability of the Cronic exception. The Court reiterated as follows:
“Cronic recognized a narrow exception to Strickland’s holding that a defendant who asserts ineffective assistance of counsel must demonstrate not only that his attorney’s performance was deficient, but also that the deficiency prejudiced the defense. Cronic instructed that a presumption of prejudice would be in order in ‘circumstances that are so likely to prejudice the accused that the cost of litigating their effect in a particular case is unjustified.’ The Court elaborated: ‘[I]f counsel entirely fails to subject the prosecution’s case to meaningful adversarial testing, then there has been a denial of Sixth Amendment rights that makes the adversary process itself presumptively unreliable.’ We illustrated just how infrequently the ‘surrounding circumstances [will] justify a presumption of ineffectiveness’ in Cronic itself. In that case, we reversed a Court of Appeals ruling that ranked as prejudicially inadequate the performance of an inexperienced, under-prepared attorney in a complex mail fraud trial.”
Id. at 190, 125 S.Ct. at 562 (citations omitted).
This Court has recognized the narrow reach of Cronic in analyzing ineffective assistance of counsel claims. See e.g., Redman v. State, 363 Md. 298, 311, 768 A.2d 656, 663 (2001). In Redman, we embraced the following interpretation of Cronic, as stated by the United States Court of Appeals for the First Circuit:
“In our view, the Court’s language in Cronic was driven by the recognition that certain types of conduct are in general so antithetical to effective assistance—for example, lawyers who leave the courtroom for long stretches of time during trial are unlikely to be stellar advocates in any matter'—that a case-by-case analysis simply is not worth the cost of [250]*250protracted litigation. No matter what the facts of a given case may be, this sort of conduct will almost always result in prejudice. But attorney errors particular to the facts of an individual case are qualitatively different. Virtually by definition, such errors ‘cannot be classified according to likelihood of causing prejudice’ or ‘defined with sufficient precision to inform defense attorneys correctly just what conduct to avoid.’ Consequently, the Court has declined to accord presumptively prejudicial status to them.”
Redman, 363 Md. at 311-12, 768 A.2d at 663 (quoting Scarpa v. DuBois, 38 F.3d 1, 12-13 (1st Cir.1994)) (citations omitted).
Similarly, the Court of Special Appeals rejected Walker’s argument that prejudice should be presumed under Cronic. The court reasoned as follows:
“The facts in this case are more similar to the facts of Warner [v. Ford, 752 F.2d 622 (11th Cir.1985)] than the facts of Martin [v. Rose, 744 F.2d 1245, 1250-51 (6th Cir.1984)]. Though Walker professed his innocence before trial, and continues to deny that he was guilty of the charges brought against him, the documentary and testimonial evidence against him was ‘overwhelming.’ [Petitioner] was one of three co-defendants, and though his own attorney did not actively participate in trial, counsel for Ms. Hall did challenge the case presented by the State. Finally, [defense counsel] had six months to prepare for the trial. He received ‘voluminous’ discovery, and discussed the case with his client several times prior to [petitioner’s] flight from the country. Furthermore, [defense counsel] testified that he was prepared to actively represent [petitioner] at trial, but chose not to deliberately because of [petitioner’s] absence. Under the reasoning of the Eleventh Circuit set forth in Warner, prejudice should not be presumed in this case.”
Walker v. State, 161 Md.App. 253, 270-71, 868 A.2d 898, 908 (2005). In addition, the court pointed out the practical effect of applying the Cronic standard as essentially abolishing trial in absentia. The court noted as follows:
[251]*251“We fear that if we allow a new trial in this case, it will open the door for criminal defendants to engineer an ‘automatic’ new trial by failing to appear for trial. If defense counsel, with or without consent, then chooses not to participate, and if the defendant is not successful on direct appeal, the defendant will obtain a new trial on ineffective assistance of counsel grounds. We decline to open the door for such manipulation of the system.”
Id. at 273, 868 A.2d at 910. We agree with the Court of Special Appeals and also reject petitioner’s argument. Defendants would have a “foolproof defense” for a new trial if prejudice were presumed in every case in which the defense counsel with an absent client elects to remain silent or participate minimally. Cf. Toomey v. Bunnell, 898 F.2d 741, 744 n. 2 (9th Cir.1990); Harding v. Lewis, 834 F.2d 853, 859 (9th Cir.1987).
Courts around the country have interpreted Cronic veiy narrowly, thereby requiring a showing of actual prejudice rather than presuming prejudice. See, e.g., Moss v. Hofbauer, 286 F.3d 851, 862 (6th Cir.2002) (refusing to apply Cronic where defense counsel failed to make an opening statement, cross-examine two witnesses, make objections, and call defense witnesses, because the omitted conduct was “not the equivalent of being physically or mentally absent” from the courtroom); Chadwick v. Green, 740 F.2d 897, 901 (11th Cir.1984) (holding that “when Cronic and [Strickland ] are read in conjunction, it becomes evident that Cronic’s presumption of prejudice applies to only a very narrow spectrum of cases where the circumstances leading to counsel’s ineffectiveness are so egregious that the defendant was in effect denied any meaningful assistance at all”). See also Turrentine v. Mullin, 390 F.3d 1181, 1207-09 (10th Cir.2004); James v. Harrison, 389 F.3d 450, 454-56 (4th Cir.2004); Fink v. Lockhart, 823 F.2d 204, 206 (8th Cir.1987); United States v. Sanchez, 790 F.2d 245, 254 (2d Cir.), cert. defined, 479 U.S. 989, 107 S.Ct. 584, 93 L.Ed.2d 587 (1986); State v. Davlin, 265 Neb. 386, 658 N.W.2d 1, 13 (2003).
[252]*252In the instant case, as a result of Walker’s and Lee’s failure to appear for trial, defense counsel found himself in the unenviable position of having to represent absent defendants. As a trial strategy, he decided essentially to remain silent, to protect the record as best as he could under the circumstances, to participate minimally, and to argue jury nullification—the latter of which the Circuit Court did not allow. Under the circumstances presented herein, the strategy counsel employed was not such that it falls within the narrow exception to warrant a presumption of prejudice. Defense counsel’s conduct was not “so antithetical to effective assistance” that the Cronic presumption of prejudice should apply. See Scarpa, 38 F.3d at 12. Moreover, his conduct did not amount to the complete failure of representation at every aspect of the trial proceeding, as contemplated by the Bell Court. See Bell, 535 U.S. at 697, 122 S.Ct. at 1851.
In a motions hearing on January 18, 1993, defense counsel argued forcefully that Walker did not “acquiesce” to be tried in absentia. Prior to the beginning of Walker’s trial, on January 19, 1993, defense counsel, once again, argued vehemently that trial of Walker in absentia was unfair and in violation of the Sixth Amendment to the United States Constitution and Article 21 of the Maryland Declaration of Rights, and announced that he would not “in any way participate in the trial.” Counsel characterized his decision not to participate in the proceedings as a strategic choice because he “unhesitatingly believed that [his clients] would not want [him] in any way to participate further at this trial,” and that he could not participate in the trial “by cross-examining witnesses, without having the benefit of [his clients next to him]” to obtain information and engage in consultations.
The following exchange occurred between Walker’s post-conviction counsel and defense counsel at Walker’s post-conviction proceeding on July 31, 2003 regarding defense counsel’s trial representation of Walker:
“[POST CONVICTION COUNSEL]: You have put on the record that you believe that your clients would not want you in any way to participate.
[253]*253[DEFENSE COUNSEL]: That is correct.
[POST CONVICTION COUNSEL]: That was done though, was it not, sir, without any consultation with Mr. Walker?
[DEFENSE COUNSEL]: That is correct.
[POST CONVICTION COUNSEL]: And without any consultation with, since you had two clients at that time, Ms. Walker.
[DEFENSE COUNSEL]: That is correct.
[POST CONVICTION COUNSEL]: That was your opinion.
[DEFENSE COUNSEL]: Absolutely.
[POST CONVICTION COUNSEL]: But your opinion was not based upon legal research as to what your duty was as opposed to what you thought you should do, correct?
[DEFENSE COUNSEL]: My opinion on that specific question was [based on] my conversations with my clients and how they viewed the trial, at least to that statement, that I believe that my clients would not want me to participate. That was my own belief.
[POST CONVICTION COUNSEL]: That was because you had, had discussions prior to trial. Mr. Walker believed that this was, in some respects a racist proceeding against him. He had an interracial marriage, correct?
[DEFENSE COUNSEL]: That is correct.
[POST CONVICTION COUNSEL]: And he had no great love for [the prosecutor] correct?
[DEFENSE COUNSEL]: That was an understatement, yes.”
This post-conviction colloquy further supports the conclusion that defense counsel’s minimal participation was a strategic decision, borne out of unusual circumstances, rather than a constructive denial of counsel, which would require a presumption of prejudice under Cronic. See Martin v. McCotter, 796 F.2d 813, 820 (5th Cir.1986) (concluding “that counsel’s decision to forego argument at the sentencing phase of Martin’s trial did not constitute a constructive denial of counsel such as to render a showing of Strickland prejudice unnecessary”); [254]*254Vickers v. State, 320 Ark. 437, 898 S.W.2d 26, 28 (1995) (recognizing that “matters of trial tactics and strategy, which can be matters of endless debate by experienced advocates, are not grounds for post-conviction relief”). Defense counsel further testified at the post-conviction proceeding that he had been Walker’s counsel for approximately six months, had conducted “voluminous discovery” and had “many, many conversations” with Walker before Walker absconded. Counsel was prepared to actively represent Walker, and once Walker absconded, counsel’s decisions were grounded in what he thought his client would want, based on his interactions with him prior to trial.
Petitioner directs our attention to a few cases in which courts have held that the attorney’s refusal to participate in the trial justified application of a presumption of prejudice under the Sixth Amendment. See United States v. Swanson, 943 F.2d 1070 (9th Cir.1991); Martin v. Rose, 744 F.2d 1245 (6th Cir.1984); State v. Harvey, 692 S.W.2d 290 (Mo.1985). We find these cases distinguishable from the case sub judice.
In United States v. Swanson, 943 F.2d 1070 (9th Cir.1991), the defendant was charged with armed robbery. Defense counsel acknowledged his client’s guilt in closing argument, conceding the element of intimidation and that his client was the perpetrator of the offense. Id. at 1074. Furthermore, he informed the jury repeatedly that the defendant’s guilt beyond a reasonable doubt could not be questioned. See id. at 1076-1078. The United States Court of Appeals for the Ninth Circuit viewed this conduct as constructive denial of counsel during a critical stage of the proceeding, thereby warranting a presumption of prejudice under Cronic. See id. at 1075-76. The court reasoned that when the defense attorney argued to the jury that no reasonable doubt existed, the defense “shouldered part of the government’s burden of persuasion.” The court pointed out that the government failed to identify any strategy that could justify defense counsel’s “betrayal of his client.” Id. at 1075. Here, Walker’s attorney determined that the best strategy was not to actively participate. He neither [255]*255conceded his client’s guilt nor shouldered the State’s burden of proof.
In State v. Harvey, 692 S.W.2d 290 (Mo.1985), prior to jury selection, defense counsel requested a continuance, noting that he was “totally unprepared” to begin the defense of his client in a capital murder case. Id. at 291. Upon the court’s denial of his request, defense counsel announced his intention to only sit at the counsel table, and not participate, asserting that he was unprepared and physically exhausted because of his work in another capital murder case. Id. At both trial and sentencing, defense counsel remained almost entirely mute, participating only in voir dire and filing various post-trial motions. Id. at 293. In the sentencing phase, counsel presented no evidence as to mitigation. Id. at 292-93. On direct appeal, the Missouri Supreme Court rejected the contention that defense counsel’s minimal participation in the proceedings was a strategic choice, consented to by the defendant, and thus, held that the defendant was constructively denied counsel within the meaning of Cronic. Id,, at 293. An important factor in the court’s decision was that the defendant was present during the trial, and the trial court had not inquired as to whether the defendant knowingly and voluntarily was relinquishing his right to effective assistance of counsel. See id. at 293.
In the case sub judice, trial counsel had represented Walker for six months, conducted discovery, and was prepared to put on Walker’s defense. It was the defendant who impeded this representation by failing to appear for trial. Furthermore, in Harvey, defense counsel did not discuss this strategy of non-representation with his client, while in the instant case, defense counsel assumed attorney silence was the strategy Walker would want him to employ under the circumstances. In sum, Walker’s attorney made a strategic calculation in an unusual situation, which is a far cry from Harvey’s counsel, who was unprepared and searching for a way out of the case.
In Martin v. Rose, 744 F.2d 1245 (6th Cir.1984), the defendant was indicted for the offenses of criminal sexual conduct in [256]*256the first degree, incest, sodomy, and crimes against nature, arising from an incident involving him and his two minor stepdaughters. Id. at 1247. The trial court denied defense counsel’s motion to dismiss and motion for a continuance—in which he alleged that he was unprepared to the try case. Id. Thereafter, defense counsel, without fully explaining the situation to his client or obtaining his client’s consent, did not cross-examine any state witnesses, make any objections, call any witnesses for the defense, make any closing argument, or object to any part of the court’s charge to the jury. Id. On appeal from denial of habeas relief, the United States Court of Appeals for the Sixth Circuit held that this “lack of participation deprived Martin of effective assistance of counsel at trial as thoroughly as if [counsel] had been absent,” warranting a Cronic presumption of prejudice. Id. at 1250-51. The court held that even though counsel’s actions were unquestionably trial strategy, they did not constitute sound trial strategy. Id. at 1249. The court reasoned that: Martin had denied participation in the offense; he had a strong defense that he could present; he had no criminal record and could take the stand and testify on his own behalf, and that the State’s case, based solely on the step-daughters’ testimony, could have been challenged by cross-examination. Id. at 1250-51.
In the instant case, Walker’s post-conviction counsel does not allege which arguments the jury did not hear and which evidence it did not see by trial counsel’s failure to participate more fully in Walker’s trial. In Martin, attorney silence was an unreasonable trial tactic for a client on trial for criminal sexual conduct because had Martin’s attorney participated, “Martin could have testified that he did not commit the crimes with which he was charged ... [and] [e]ven if Martin had not testified, the girls’ testimony could have been subjected to cross-examination or questioned in final argument.” Id. at 1250-51. Unlike, Martin, the case against Walker was built upon substantial documentary and testimonial evidence. Here, the record reflects no defense Walker could have asserted if counsel had behaved differently.
[257]*257Moreover, in the instant case, defense counsel argued repeatedly to the Circuit Court that trial in absentia was unconstitutional, cited rules to the Court, attended bench conferences during the trial, sought to make a closing argument, and responded to the Court’s inquiries regarding admission of State exhibits. As the State points out, counsel for co-defendant Hall challenged the State’s evidence in front of the jury, which was to the benefit of all three defendants.
We note that in the cases cited by petitioner, each defendant was present at trial and never waived his right to effective assistance of counsel. Even if a defendant absconds prior to trial, the right to effective assistance of counsel is not waived automatically. As petitioner points out, it is well-established that a defendant’s waiver of the Sixth Amendment right to counsel must be knowing and intelligent. See Faretta v. California, 422 U.S. 806, 835, 95 S.Ct. 2525, 2541, 45 L.Ed.2d 562 (1975); State v. Renshaw, 276 Md. 259, 265-66, 347 A.2d 219, 224 (1975). By failing to appear, however, the defendant puts the attorney in the difficult position of deciding how best to put on a defense if a continuance is denied and the trial judge proceeds in absentia. Whether non-participation or silence is a reasonable strategy should depend upon the circumstances of each case. See Warner v. Ford, 752 F.2d 622, 625 (11th Cir.1985).
“Silent strategy” is the phrase often used to describe an attorney’s decision either not to participate at trial or to participate minimally. Cf. Warner, 752 F.2d at 625; Walker I, 338 Md. at 261, 658 A.2d at 243; Keith Cunningham-Parmeter, Dreaming of Effective Assistance, 76 Temp. L.Rev. 827, 869-875 (2003). Some courts have recognized an attorney’s decision to remain silent as a legitimate, strategic choice worthy of deference under Strickland. See generally United States v. Sanchez, 790 F.2d 245 (2nd Cir.), cert denied, 479 U.S. 989, 107 S.Ct. 584, 93 L.Ed.2d 587 (1986) (applying Strickland, to defendant’s ineffective assistance of counsel claim where defendant had absconded prior to trial and trial counsel’s participation was limited to objection to trial in [258]*258absentia and a flight instruction and to moving for judgment of acquittal); Warner v. Ford, 752 F.2d 622 (11th Cir.1985) (applying Strickland to defendant’s ineffective assistance of counsel claim, where trial counsel’s participation was limited to a motion for a directed verdict, a request for a mistrial, and a recommendation that his client not take the witness stand). See also Martin v. McCotter, 796 F.2d 813 (5th Cir.1986) (applying Strickland to defendant’s ineffective assistance of counsel claim, where trial counsel remained silent at the sentencing phase of his client’s trial).
In Warner v. Ford, 752 F.2d 622 (11th Cir.1985), the United States Court of Appeals for the Eleventh Circuit considered a claim of ineffective assistance of counsel involving defense counsel’s silence during trial in the face of overwhelming evidence of guilt. Id. at 625. Two co-defendants were tried in the same proceeding with Warner, and Warner was convicted of four counts of armed robbery. Id. at 623-24. Warner’s attorney did not participate in the trial, except to move for a directed verdict on one count, request a mistrial three times, and recommend that his client not take the stand when his client was called by his co-defendants to testify in their defenses. Id. at 624. On appeal from the District Court’s denial of habeas, the Eleventh Circuit applied the Strickland analysis to Warner’s claim of ineffective assistance of counsel, deciding that a case-by-case inquiry is more suitable than a presumption of prejudice, when the “silent strategy” is at issue. Id. at 625. The Eleventh Circuit explained as follows:
“Silence can constitute trial strategy. Whether that strategy is so defective as to negate the need for a showing of prejudice to establish ineffective assistance of counsel must be judged on a case-by-case basis. [Strickland ] has established that courts ‘must indulge a strong presumption that counsel’s conduct falls within the wide range of professional assistance.’ Thus, in order for a petitioner with an ineffective assistance claim to prevail over his former counsel’s assertion of strategy, he must overcome the presumption that, under the circumstances, the challenged action ‘might be considered sound trial strategy.’ ”
[259]*259Id. at 625 (citations omitted). The Warner Court concluded that defense counsel’s representation of Warner was not so defective as to entitle Warner to relief without any showing that his attorney’s conduct prejudiced him. Id.
In United States v. Sanchez, 790 F.2d 245 (2d Cir.), cert. denied, 479 U.S. 989, 107 S.Ct. 584, 98 L.Ed.2d 587 (1986), Sanchez did not appear for trial on the scheduled date. His attorney, the co-defendant, and the co-defendant’s attorney were present, and the trial proceeded in Sanchez’s absence. Id. at 248. Defense counsel engaged in “limited defense activity,” consisting of objecting to the trial itself, a request for a flight instruction, and a motion for judgment of acquittal. Id. at 248, 253. The jury returned a verdict of guilty against Sanchez on two counts, and Sanchez claimed ineffective assistance of counsel. Id. at 248.
The United States Court of Appeals for the Second Circuit rejected Sanchez’s ineffective assistance of counsel claim, refusing to invoke Cronic where a “defendant by his own obstructive conduct precludes his counsel from pursuing an intelligent [and] active defense.” Id. at 254. The Second Circuit recognized the silent strategy as appropriate in some cases, noting as follows:
“Here, there is no evidence that Sanchez made any effort to communicate with or otherwise cooperate with his attorney. There is no evidence that Sanchez consulted with his attorney regarding his decision not to attend the trial, and not to be available during the weeks preceding trial. Where an attorney is confronted with such a client, whose uncooperativeness precludes any reasonable basis for an active defense, the strategy of silence—perhaps in hopes that the government will produce insufficient evidence or that the government or court will commit reversible error—may actually constitute a defense strategy. Certainly, the right to counsel does not impose upon a defense attorney a duty unilaterally to investigate and find evidence or to pursue a fishing expedition by cross-examination, or to present opening or closing remarks on the basis of no helpful informa[260]*260tion, or to object without purpose, on behalf of an uncooperative and unavailable client.”
Id. at 253 (citations omitted).
Simply because “silence” is the product of trial strategy, however, does not insulate attorney conduct from review. Strategic decisions must nonetheless be supported by reasonable professional judgment. See Strickland v. Washington, 466 U.S. 668, 690, 104 S.Ct. 2052, 2066, 80 L.Ed.2d 674 (1984). Whether “silence” as a strategy is reasonable is to be determined on a case by case basis, under the standards set forth in Strickland. See id. at 691, 104 S.Ct. at 2066 (noting that “the reasonableness of counsel’s actions may be determined or substantially influenced by the defendant’s own statements or actions. Counsel’s actions are usually based, quite properly, on informed strategic choices made by the defendant and on the information supplied by the defendant”).
We hold that the post-conviction court did not err in rejecting the Cronic standard in this case and that Strickland v. Washington provides the proper framework for review of Walker’s ineffective assistance of counsel claim under the Sixth Amendment.
JUDGMENT OF THE COURT OF SPECIAL APPEALS AFFIRMED.
COSTS IN THIS COURT AND THE COURT OF SPECIAL APPEALS TO BE PAID BY PETITIONER.
BELL, C.J., dissents.