(Zervas). 116 . See id. 117 . See A-3 69:4-A-370:19 (Zervas). 118 . Williams v. Taylor, 529 U.S. 362, 396, 120 S.Ct. 1495, 146 L.Ed.2d 389 (2000). Under the guidelines propounded by the American Bar Association, counsel is to seek mitigating evidence even if the client initially states that he does not want to offer such evidence. Am. Bar Assn, Guidelines for the Appointment and Performance of Counsel in Death Penalty Cases % 11.4.1 (1989). 119 . Strickland v. Washington, 466 U.S. 668, 688, 104 S.Ct. 2052, 80 L.Ed.2d 674 (1984); see Ploof III, 2012 WL 1413483, at *8. 120 . Ploof III, 2012 WL 1413483 at *8. 121 . Rompilla v. Beard, 545 U.S. 374, 395, 125 S.Ct. 2456, 162 L.Ed.2d 360 (2005). 122 . See generally Wiggins v. Smith, 539 U.S. 510, 123 S.Ct. 2527, 156 L.Ed.2d 471 (2003) (<HOLDING>). 123 . See Strickland, 466 U.S. at 687, 104
holding that to demonstrate deficient performance a petitioner must show counsel made errors so serious that counsel was not functioning as the counsel guaranteed a defendant by the sixth amendment recognizing that defendant must show 1 that counsels performance was deficient and 2 that counsels errors prejudiced the defense holding that trial counsels performance in failing to object move to strike or request an admonishment of the jury with respect to the defendants criminal history was deficient and that it could not be said that the references to the defendants criminal history did not impact the jurys decision where the evidence was not overwhelming and reversing for a new trial holding that the failure to recognize every possible legal argument did not render counsels performance constitutionally deficient holding that the trial counsels performance was constitutionally deficient where counsel made a limited investigation into the petitioners background did not prepare a social history of the petitioner and was not aware that he had been sexually abused and raped as a child