The following excerpt is from Fuller v. Roe, 182 F.3d 699, 1999 WL 462632 (9th Cir. 1999):
A claim for ineffective assistance of counsel is cognizable as a claim of denial of the Sixth Amendment right to counsel. See Strickland v. Washington, 466 U.S. 668, 686 (1984). The benchmark for judging a claim of ineffectiveness of counsel must be whether counsel's conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied upon as having produced a just result. See id. First, the defendant must show that counsel's performance was deficient to the point where the errors made were so serious that counsel was not functioning as the counsel guaranteed under the Sixth Amendment. See id. at 687.
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