What is the range of relief for a defendant in a civil case where counsel made tactical decisions that were deemed unenforceable?

MultiRegion, United States of America

The following excerpt is from Furman v. Wood, 190 F.3d 1002 (9th Cir. 1999):

Relief will be granted if counsel's performance fell outside a wide range of reasonableness and defendant was prejudiced. Strickland v. Washington, 466 U.S. 668, 687, 694 (1984). Counsel's tactical decisions are "virtually unchallengeable." Id. at 690.

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