Strickland v. Washington (1984):
“A
convicted defendant's claim that counsel's assistance was so
defective as to require reversal of a conviction or death sentence
has two components. First, the defendant
must show that counsel's performance was deficient. This
requires showing that counsel made errors so serious that
counsel was not functioning as the "counsel" guaranteed the
defendant by the Sixth Amendment. Second, the defendant must
show that the deficient performance prejudiced the defense. This
requires showing that counsel's errors were so serious as to
deprive the defendant of a fair trial, a trial whose result is
reliable. Unless a defendant makes
both showings, it cannot be said that the conviction or death
sentence resulted from a breakdown in the adversary process that
renders the result unreliable.”
(1) Nature of the Error Prong
Whether the counsel’s performance was deficient under the
circumstances with performance measured under the standard of
prevailing professional norms and
(2) Prejudice Prong
Whether the lawyer's conduct affected, with reasonable
probability, the trial's outcome - this relies upon but-for
causation: "but for counsel's unprofessional errors, the
results of the proceeding would have been different."