The following excerpt is from SPENCE v. YATES, No. 1:08-cv—00045-AWI-SKO-HC (E.D. Cal. 2011):
The law governing claims concerning ineffective assistance of counsel is clearly established for the purposes of the AEDPA deference standard set forth in 28 U.S.C. 2254(d). Canales v. Roe, 151 F.3d 1226, 1229 n.2 (9th Cir. 1998).
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