California, United States of America
The following excerpt is from The People v. Robert Eugene Wash., F056938, No. RF005212A (Cal. App. 2010):
Appellant cites Commonwealth v. Mikell (1999) 556 Pa. 509 [729 A.2d 566] as a case in which counsel's "failure to request an alibi instruction constituted constitutionally ineffective assistance of counsel such as to entitle [defendant] to a new trial." (Id. at p. 518 [729 A.2d at p. 571].) Appellant has cited, and we have located, no California case in which a defense attorney's failure to request an alibi instruction was determined to violate a defendant's right to effective assistance of counsel.
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