Is there an evidentiary hearing to determine if counsel breached their duty of loyalty by calling a client a "stupid nigger son of a bitch"?

Bonin cites Frazer v. United States, 18 F.3d 778 (9th Cir.1994) (Frazer ), but Frazer is clearly inapplicable. Frazer testified that his attorney called him a "stupid nigger son of a bitch and said he hopes I get life." Id. at 780. Worse yet, the attorney threatened to "be very ineffective" if his client insisted on going to trial. Id. While the facts of Frazer supported the need for an evidentiary hearing to determine if counsel breached his duty of loyalty and denied his client effective assistance of counsel, the same cannot be said merely because an attorney expresses dislike for a client. If being liked by one's lawyer were a sine qua non of effective representation, some clients might never be effectively represented. Thus, the district court did not abuse its discretion by refusing to hold an evidentiary hearing on this issue.