To show deficient performance, counsel’s actions or omissions must be measured against what “an objectively reasonable attorney would have done under the circumstances existing at the time of the representation.” Savino v. Murray, 82 F.3d 593, 599 (4th Cir.1996); see also Lawrence v. Branker, 517 F.3d 700, 708-09 (4th Cir.2008). The court must attempt to “eliminate the distorting effects of hindsight,” and instead “indulge a strong presumption that counsel’s challenged conduct falls within the wide range of reasonable professional assistance.” Strickland, 466 U.S. at 689, 104 S.Ct. 2052. The right to effective assistance of counsel includes the duty of counsel to communicate formal plea offers from the prosecution. See Missouri v. Frye, — U.S. -, 132 S.Ct. 1399, 182 L.Ed.2d 379 (2012) (<HOLDING>); see also Lafler v. Cooper, — U.S. -, 132
holding that defense counsel had duty to communicate formal offer from the prosecution to accept a plea on terms and conditions that may be favorable to the accused holding that a  1983 due process claim that essentially contests the fairness of the plaintiffs prosecution  is  similar to his malicious prosecution claim and claims resembling malicious prosecution do not accrue until the prosecution has terminated in the plaintiffs favor  holding that defense counsel has the duty to communicate formal offers from the prosecution holding that defense counsel opened the door to the prosecutions questioning of the defendant about prior convictions when defense counsel asked a prosecution witness whether he was aware that the defendant was  a convicted felon holding that defense counsel opened the door to the states rebuttal remarks when defense counsel raised the issue in his closing argument