Can a client be charged with abandonment of an attorney who failed to communicate to the client about a key development in his client's case?

^3. Maples v. Thomas clarified Holland's distinction between "garden variety" attorney negligence and egregious attorney misconduct. 565 U.S. 266, 282-83 (2012). Maples explained that while agency law binds clients, including federal habeas petitioners, to their attorneys' negligence, "a client cannot be charged with the acts or omissions of an attorney who has abandoned him." Id. at 283. An attorney's failure to communicate about a key development in his client's case can, therefore, amount to attorney abandonment and thereby constitute an extraordinary circumstance. Id. at 282-83.