The Supreme Court assumes effective counsel unless conduct undermines the trial process. To claim ineffective counsel, one must show: (1) counsel's deficient performance and (2) a reasonable probability that competent counsel would have led to a different outcome. Demonstrating the second point is difficult because it requires proving the hypothetical outcome with competent counsel.

1. Assistance of Counsel
The Court assumes that effective assistance of counsel is present unless the adversarial
process is so undermined by counsel’s conduct that the trial cannot be relied upon to have
produced a just result. An accused who claims ineffective counsel must show the following:
(1) deficient performance by counsel and (2) a reasonable probability that a competent
attorney would have led to a different outcome (Strickland v. Washington, 466 U.S. 668
[1984]). Discuss the difficulty of successfully demonstrating point number two. Please
articulate WHY in your answers