The following excerpt is from Souliotes v. Grounds, 1:06-cv-00667 AWI MJS HC (E.D. Cal. 2013):
Here, the state court explained that "[a] petition for habeas corpus can't be used to second guess trial attorneys strategy during the trial." This statement reflects a belief that the state court lacked authority on habeas review to adjudicate questions of strategy of counsel. If the court felt it could not review questions of strategy, then it necessarily failed to determine if counsel's strategy fell below an objective standard of reasonableness. "The relevant question is not whether counsel's choices were strategic, but whether they were reasonable." Roe v. Flores-Ortega, 528 U.S. 470, 481 (2000).
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