What is the state of the law in relation to the strategic decisions of counsel in the context of a claim of ineffective assistance on habeas review?

MultiRegion, United States of America

The following excerpt is from Samuel v. Lavalley, No. 13-723-pr (2nd Cir. 2014):

Where the claimed constitutional error on habeas review is ineffective assistance of counsel, a second level of deference applies to the strategic decisions of counsel, unless petitioner can show that (1) counsel's performance was objectively deficient, and (2) he suffered ensuing prejudice. See Strickland v. Washington, 466 U.S. 668, 688, 692-93 (1984). With respect to the first prong, we "indulge a strong presumption that counsel's conduct falls within the wide range of reasonable professional assistance." Id.

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