What are the grounds for ineffective assistance of counsel in a sexual assault case?

The district court denied relief on grounds 1 and 12 on the merits. In ground 1, petitioner argues that the state trial court improperly quantified reasonable doubt in explaining the standard to the jury during voir dire, thereby violating due pro-cess. In ground 12, petitioner argues that his trial counsel's failure to object to the introduction, at the sentencing phase, of evidence of petitioner's kidnapping of his fiancee constituted ineffective assistance of counsel under Strickland v. Washington, 466 U.S. 668 (1984), because the kidnapping did not constitute a prior "conviction."