What is the test for ineffective counsel in a civil case?

Even if we were to reach the issue, defendant has failed to show his entitlement to relief. The right to effective assistance of counsel derives from the Sixth Amendment right to assistance of counsel. (Strickland v. Washington (1984) 466 U.S. 668, 686-694; see also Cal. Const., art. I, 15.) To demonstrate ineffective assistance, defendant must show (1) counsel's conduct was deficient when measured against the standards of a reasonably competent attorney, and (2) prejudice resulting from counsel's performance so undermined the proper functioning of the adversarial process that the trial cannot be relied on

Page 9