What is the test for ineffective representation in a civil case?

Jaafar, a citizen of Lebanon, argues that his prior counsel rendered constitutionally ineffective assistance by failing to advise him of the immigration consequences of pleading guilty. We analyze claims of ineffective assistance of counsel under the two-prong standard set forth in Strickland v. Washington, 466 U.S. 668 (1984). Under that standard, the defendant has the burden to establish (1) that counsel's representation "fell below an objective standard of reasonableness" as measured under "prevailing professional norms," and (2) that "there is a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been different." Id. at 688, 694.

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