The following excerpt is from Rose v. Santoro, No. 2:13-cv-02416-JKS (E.D. Cal. 2015):
Rose additionally alleges that trial counsel was ineffective with regard to the photographic lineup and identification offered at trial. To demonstrate ineffective assistance of counsel under Strickland v. Washington, a defendant must show both that his counsel's performance was deficient and that the deficient performance prejudiced his defense. 466 U.S. 668, 687 (1984). A deficient performance is one in which "counsel made errors so serious that counsel was not functioning as the 'counsel' guaranteed by the Sixth Amendment." Id.
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