What is the test for a claim of ineffective counsel in a civil case?
California, United States of America
The following excerpt is from People v. Banks, F073608 (Cal. App. 2018):
purpose for the challenged act or omission, (2) counsel was asked for a reason and failed to provide one, or (3) there could be no satisfactory explanation for counsel's choices. All other claims of ineffective assistance of counsel are more appropriately resolved in a habeas corpus proceeding. (People v. Mai (2013) 57 Cal.4th 986, 1009.)
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