Does a defendant have to prove that she received ineffective assistance of counsel before entering her plea?

Defendant also argues she received ineffective assistance of counsel before entering her plea, asserting that her attorney failed to investigate her case adequately, failed to advise her about the charges, and failed to advise her about a potential alibi defense. To establish a claim of ineffective assistance of counsel in the context of a guilty plea, a defendant must show both that counsel's performance fell below an objective standard of reasonableness and that she suffered prejudice, in that "there is a reasonable probability that, but for counsel's errors, [s]he would not have pleaded guilty and would have insisted on going to trial. (Hill v. Lockhart (1985) 474 U.S. 52, 59.)

In Premo v. Moore (2011) _ U.S. _ [131 S.Ct. 733, 178 L.Ed.2d 649], the court recognized that "[i]n the case of an early plea [as occurred in the instant case], neither the prosecution nor the defense may know with much certainty what course the case may

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take. It follows that each side, of necessity, risks consequences that may arise from contingencies or circumstances yet perceived. The absence of a developed or an extensive record and the circumstance that neither the prosecution nor the defense case has been well defined create a particular risk that an after-the-fact assessment will run counter to the deference that must be accorded counsel's judgment and perspective when the plea was negotiated, offered, and entered." (Premo v. Moore, supra, ___ US ___, 131 S.Ct. at p. 742.)