There are two prongs to the test of ineffective assistance of counsel. To prove the first prong, the defendant must show that counsel's actions fell below an objective standard of reasonableness. In this regard, the court's scrutiny of counsel's performance is highly deferential, and the court must make every effort to evaluate the conduct from counsel's perspective at the time. To prove the second prong, the defendant must show that there is a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been different. A reasonable probability is a probability sufficient to undermine confidence in the outcome of the proceeding.
Defendant was found guilty of distribution of heroin and received a mandatory sentence of life imprisonment. Defendant filed a petition for habeas relief alleging that she was denied effective assistance of counsel. The district court granted habeas relief and ordered a retrial after finding that defendant had demonstrated prejudice due to her counsel's deficient performance, or alternatively, that she had been denied her constitutional rights due to inadequate representation. The state appeals from the District Court's grant of the defendant's habeas relief petition.
Did defendant show that there was a reasonable probability that, but for her counsel's errors, the result of her trial would have been different.
In reversing the lower court's grant of the defendant's habeas petition, the 5th Circuit found that the defendant had failed to exhaust her ineffective assistance claims in state court. On the merits of the case, the court found that the defendant's counsel had subjected the prosecution's case to meaningful adversarial testing, so defendant had to show prejudice under the Strickland test. The court found that the evidence of defendant's guilt was overwhelming, and defendant had not been prejudiced by her counsel's performance.