People v. Ford

In People v. Ford, 205 AD2d 310, 311, 612 N.Y.S.2d 575 (1st Dept. 1994), the First Department summarily answered that question, holding that "[d]efendant was not denied effective assistance of counsel by his counsel's appropriate strategic concessions in summation ..., notwithstanding defendant's disagreement with counsel's strategy." Thus, even had the defendant explicitly objected to the strategy trial counsel employed in his summation, using it over the defendant's objection would not have constituted ineffective assistance of counsel.