§ 4.28.1 Ineffective Assistance of Counsel. The most common ground urged in post-conviction relief cases is ineffective assistance of counsel. Such claims can be made under both the federal and state constitution, and, thus, they fall under Rule 32.1(a). The U.S. Constitution’s Sixth and Fourteenth Amendments guarantee a defendant who has the right to counsel in a state proceeding the fundamental right to “effective” assistance of counsel. See U.S. CONST., AMEND. VI; see also Strickland v. Washington, 466 U.S. 668, 687 (1984) (setting forth standard for federal ineffective-assistance-of-counsel claims); State v. Nash, 143 Ariz. 392, 397, 694 P.2d 222, 227 (1985) (adopting Strickland standard for ineffective-assistance-of-counsel claims). The Arizona Constitution also guarantees the right to effective assistance of counsel. See ARIZ. CONST., art. II, § 24; State v. Jenkins, 148 Ariz. 463, 465, 715 P.2d 716, 718 (1986); see also Rule 6.1 (relating to appointment of counsel).
In Arizona, a Rule 32...
