not credit. Id. at 1268. Smith’s lawyer failed to investigate or present any mitigating evidence,. despite the availability of evidence that Smith had an antisocial personality disorder, a bad drug history, and some close family relationships. Id. at 1269. Although this court recognized that these mitigating factors were often treated on appeal as insufficient to justify mitigation, the court could think of no tactical reason for counsels’ deficient closing contributed to the cumulative prejudice caused by the other errors at sentencing. Under prevailing case law, individual deficiencies in representation which may not by themselves meet the Strickland standard may, when considered cumulatively, constitute sufficient prejudice to justify issuing the writ. See Harris, 64 F.3d at 1438-39 (<HOLDING>); Mak v. Blodgett, 970 F.2d 614, 622 (9th
holding that a defendant alleging ineffective assistance must demonstrate that their counsels performance both fell below an objective standard of reasonableness and prejudiced the defense recognizing that defendant must show 1 that counsels performance was deficient and 2 that counsels errors prejudiced the defense holding that the cumulative impact of multiple deficiencies in defense counsels performance prejudiced the defendant in a capital trial holding pcr was properly denied where the applicant did not prove he was prejudiced by trial counsels deficient performance in failing to preserve an issue at trial recognizing that in order to prevail on a claim of ineffective assistance of counsel a movant must show that he was prejudiced by his counsels performance