What is the current state of the law in the context of ineffectiveness claims?

"In determining whether counsel's performance was deficient, a court must in general exercise deferential scrutiny" in order to avoid "the adverse consequences that systematic 'second-guessing' might have on the quality of legal representation provided to criminal defendants and on the functioning of the criminal justice system itself." (People v. Ledesma (1987) 43 Cal.3d 171, 216.) "We cautioned in Strickland that a court must indulge a 'strong presumption' that counsel's conduct falls within the wide range of reasonable professional assistance because it is all too easy to conclude that a

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particular act or omission of counsel was unreasonable in the harsh light of hindsight. [Citation.]" (Bell v. Cone (2002) 535 U.S. 685, 702 [122 S.Ct. 1843], italics added.)

"[A] court need not determine whether counsel's performance was deficient before examining the prejudice suffered by the defendant as a result of the alleged deficiencies. . . . If it is easier to dispose of an ineffectiveness claim on the ground of lack of sufficient prejudice, which we expect will often be so, that course should be followed." (Strickland v. Washington, supra, 466 U.S. at p. 697.)

b. Discussion.