What is the current state of the law on the right to counsel in a civil case?

right to counsel is meant to serve. [Citation.] . . . It is 'all too tempting' to 'second-guess counsel's assistance after conviction or adverse sentence.' [Citations.] The question is whether an attorney's representation amounted to incompetence under 'prevailing professional norms,' not whether it deviated from best practices or most common custom. [Citation.]" (Richter, supra, 562 U.S. at p. ___ [178 L.Ed.2d at pp. 642-643].) " 'Reviewing courts defer to counsel's reasonable tactical decisions in examining a claim of ineffective assistance of counsel [citation], and there is a "strong presumption that counsel's conduct falls within the wide range of reasonable professional assistance." ' [Citations.]" (People v. Weaver (2001) 26 Cal.4th 876, 925 (Weaver).)