What is the standard for ineffective assistance of counsel in federal habeas cases?

A doubly deferential standard governs a federal habeas petitioner's claim of ineffective assistance of counsel. The two-step inquiry from Strickland v. Washington guides the analysis for an ineffective-assistance-of-counsel claim. See 466 U.S. 668, 687 (1984). First, a criminal defendant must show some deficiency in performance by counsel that is "so serious that counsel was not functioning as the counsel guaranteed the defendant by the Sixth Amendment." Id. Second, the defendant must show that the deficient performance caused him prejudice. Id. This

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