Is there any case law where a plaintiff has been found to be "difficult to meet" by the Court of Appeal?

MultiRegion, United States of America

The following excerpt is from Anguiano v. Callahan, Case No.: 18cv2056-BAS (RBM) (S.D. Cal. 2019):

"Surmounting Strickland's high bar is never an easy task." Padilla v. Kentucky, 559 U.S. 356, 371 (2010). In addition, 28 U.S.C. 2254(d) presents "a 'difficult to meet' and

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