The following excerpt is from Leon v. Spearman, No. 1:14-cv-00301-DAD-SKO HC (E.D. Cal. 2017):
The scope of federal habeas review of a claim of ineffective assistance of counsel is narrow. Dows v. Wood, 211 F.3d 480, 484 (9th Cir. 2000). A habeas petitioner has the burden of
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