Is a suspended or disbarred attorney ineffective assistance of counsel?

MultiRegion, United States of America

The following excerpt is from Haro v. Borg, 996 F.2d 1224 (9th Cir. 1993):

"The fact that an attorney is suspended or disbarred does not, without more, rise to the constitutional significance of ineffective assistance of counsel under the Sixth Amendment." United States v. Mouzin, 785 F.2d 682, 696-97 (9th Cir.), cert. denied, 479 U.S. 985 (1986). In order to raise an ineffective assistance of counsel claim on the basis that the attorney had been disbarred or suspended, a petitioner must point to specific conduct which prejudiced him. Id. at 697.

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