Flakes v. Wisconsin

“decisions which fall squarely within the ambit of trial strategy ... if reasonably made, will not constitute a basis for an ineffective assistance claim” | "decisions which fall squarely within the ambit of trial strategy ... if reasonably made, will not constitute a basis for an ineffective assistance claim" | “Counsel’s decision not to call a witness, if supported by valid tactical considerations, does not constitute ineffective assistance of counsel.” | “It is common knowledge that defense counsel quite often waive openings as a simple matter of trial strategy.” | burden of showing substantial prejudice amounting to a miscarriage of justice | “[T]he fact that [the defendant] ... had no duty to report [the] transactions ... is not the operative issue as to whether he agreed to unlawfully defraud the United States by impairing and obstructing [the IRS’s] lawful governmental function[] of collecting data....”