ABA Criminal Justice Standards for the Defense Function strongly suggest that failure to consult and utilize statistics and data at sentencing may constitute ineffective assistance of counsel. See, e.g., ABA Crim. J. Stds. for the Def. Function, Std. 4-8.3(a-d) (4th Ed. 2015) (“Defense counsel’s preparation before sentencing should include learning the court’s practices in exercising sentencing discretion . . . and the normal pattern of sentences for the offense involved.”); Strickland v. Washington, 466 U.S. 668, 688 (1984) (noting that ABA standards “are guides for determining what is reasonable” in determining whether counsel was constitutionally defective).