Does Missouri v. Frye place an unreasonable burden on defendants?

QUESTIONS PRESENTED Does Missouri v. Frye, 566 U.S. 134 (2012), place an unreasonable burden upon defendants by requiring them to produce evidence to prove the counterfactual inquiries relating to prosecutorial withdrawal and judicial nonacceptance of a forgone plea offer? In resolving claims of ineffective assistance of counsel under Frye, is it more practical for courts to presume, in the typical case, that statesponsored plea offers are acceptable to the prosecutor (who extended the offer in the first place) and the trial judge, absent some identifiable indication to the contrary? ii