State v. Farook

Summary

The court held that claims alleging ineffective assistance based on counsel's unconsented concession of guilt are generally governed by the two-part deficient-performance and prejudice inquiry, rather than an automatic presumption of prejudice. The automatic-prejudice exception applies only when counsel completely fails to function as the defendant's advocate, including circumstances in which the defendant is entirely surprised by the concession. Because defendant had agreed to multiple factual concessions and could not show that the challenged concessions affected his convictions, the court reversed the Court of Appeals' remand for an evidentiary hearing.