In People v. Doolin (2009) 45 Cal.4th 390, the California Supreme Court held that a lump sum compensation agreement that included attorney's fees and costs for investigative and expert services did not create a conflict of interest adversely affecting counsel's performance. To assert a Sixth Amendment violation, the defendant must "show: (1) counsel's deficient performance, and; (2) a reasonable probability that absent counsel's deficiencies, the result of the proceeding would have been different." (Id., at p. 417.) The court in Doolin disapproved of earlier cases holding that attorney conflict claims under the California constitution may be analyzed under a standard different from that articulated by the United States Supreme Court. (Id., at pp. 419-421.) "In the context of a conflict of interest claim, deficient performance is demonstrated by a showing that defense counsel labored under an actual conflict of interest 'that affected counsel's performance -- as opposed to a mere theoretical division of loyalties.'" (Id., at p. 417.)