In Strickland v. Washington, 466 U.S. 668 (1984) the United States Supreme Court adopted a two-pronged test for ineffective assistance, holding that a defendant must show, first, "that counsel's representation fell below an objective standard of reasonableness" (466 U.S. at 688) and, secondly, "that there is a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been different" (id. at 694). Strickland holds that the minimum standard of performance required by the Sixth Amendment is a very tolerant one: "Judicial scrutiny of counsel's performance must be highly deferential. It is all too tempting for a defendant to second-guess counsel's assistance after conviction or adverse sentence, and it is all too easy for a court, examining counsel's defense after it has proved unsuccessful, to conclude that a particular act or omission of counsel was unreasonable." (466 U.S. at 689.) In Strickland v. Washington, "the Supreme Court adopted a two-part test for evaluating claims of ineffective assistance of counsel generally. A defendant must show that counsel's performance was deficient,' and that the deficient performance prejudiced the defense'". The first prong of the Strickland test is essentially a restatement of attorney competence, which requires a showing that counsel's representation fell below an objective standard of reasonableness. The second prong, also known as the prejudice prong, focuses on whether counsel's constitutionally ineffective performance affected the outcome of the plea process'. In order to satisfy this prong, a defendant must show that there is a reasonable probability that, but for counsel's errors, he would not have pleaded guilty and would have insisted on going to trial'" (People v. McDonald, 1 NY3d 109, 113-114, (2003)). In Strickland v. Washington, the Supreme Court of the United States set forth the two-pronged test for ineffective assistance of counsel. It requires that the defendant show: (1) counsel's performance was deficient; and; (2) the deficient performance prejudiced the defense. The first prong "requires showing that counsel made errors so serious that counsel was not functioning as the 'counsel' guaranteed the defendant by the Sixth Amendment." Id. at 687. The second prong "requires showing that counsel's errors were so serious as to deprive the defendant of a fair trial, a trial whose result is unreliable." Id. See, also, State v. Bradley (1989), 42 Ohio St.3d 136, 538 N.E.2d 373 (adopting Strickland). In Strickland v. Washington the United States Supreme Court stated that a court's scrutiny of an attorney's work must be highly deferential. The court further stated that it is too tempting for a defendant to second-guess his attorney after conviction and that it would be all too easy for a court to conclude that a specific act or omission was deficient, especially when examining the matter in hindsight. Accordingly, "a court must indulge a strong presumption that counsel's conduct falls within the wide range of reasonable professional assistance; that is, the defendant must overcome the presumption that, under the circumstances, the challenged action might be considered sound trial strategy." Strickland, 104 S.Ct. at 2065.