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To satisfy the first prong, the defendant must show that counsel’s representation fell below an objective standard of reasonableness.

stitutional right to counsel in criminal cases, the respondent opines that, if we were to recognize a right to effective assistance of counsel in termination of parental rights cases and apply the same standard of review, she would be required to establish both that her counsel’s performance was constitutionally deficient and that counsel’s deficient performance prejudiced the outcome of the case.

To prevail upon a claim of ineffective assistance of counsel, the defendant must demonstrate, “first, that counsel’s representation was constitutionally deficient and, second, that counsel’s deficient performance actually prejudiced the outcome of the case.” State v. Collins, 166 N.H. 210, 212 (2014).

To prevail upon a claim of ineffective assistance of counsel, the defendant must demonstrate, “first, that counsel’s representation was constitutionally deficient and, second, that counsel’s deficient performance actually prejudiced the outcome of the case.” State v. Collins, 166 N.H. 210, 212 (2014).

nsel claims and that they are permissible for direct appellate review, see State v. Brown, 166 N.H. 7 520, 522-23 (2014); cf. State v. Thompson, 161 N.H. 507, 527 (2011), such claims are insufficiently developed, as the defendant fails to consider or apply the two-part test used to evaluate ineffective assistance of counsel claims, see State v. Collins, 166 N.H. 210, 212-13 (2014).

State v. Collins, 166 N.H. 210, 212 (2014) (stating that failure to establish either prong requires a finding that counsel’s performance was not constitutionally defective).

State v. Collins, 166 N.H. 210, 212 (2014) (stating that failure to establish either prong requires a finding that counsel’s performance was not constitutionally defective).

To prevail upon his claim of ineffective assistance of counsel, the defendant must demonstrate, first, that his trial attorneys’ representation was constitutionally deficient and, second, that their deficient performance actually prejudiced the outcome of the case.

A failure to establish either prong requires a finding that counsel’s performance was not constitutionally defective.

A failure to establish either prong requires a finding that counsel’s performance was not constitutionally defective.

To prevail upon a claim of ineffective assistance of counsel, the defendant must demonstrate, first, that counsel’s representation was constitutionally deficient and, second, that counsel’s deficient performance actually prejudiced the outcome of the case.

To prevail upon a claim of ineffective assistance of counsel, the defendant must demonstrate, first, that counsel’s representation was constitutionally deficient and, second, that counsel’s deficient performance actually prejudiced the outcome of the case.

To prevail upon a claim of ineffective assistance of counsel, the defendant must demonstrate, first, that counsel’s representation was constitutionally deficient and, second, that counsel’s deficient performance actually prejudiced the outcome of the case.

“To prevail upon a claim of ineffective assistance of counsel, the defendant must demonstrate, first, that counsel’s representation was constitutionally deficient and, second, that counsel’s deficient performance actually prejudiced the outcome of the case.” State v. Collins, 166 N.H. 210, 212 (2014).

A failure to establish either prong requires a finding that counsel’s performance was not constitutionally defective.