California, United States of America
The following excerpt is from People v. Perkins, A145448 (Cal. App. 2016):
2. Perkins argues that the appropriate standard of review for the prejudice prong is whether counsel's performance was harmless beyond a reasonable doubt under Chapman v. California (1966) 386 U.S. 18. He provides no authority for this position, and we therefore do not consider it.
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