State v. Layton
In State v. Layton, 189 W. Va. 470, 432 S.E.2d 740 (1993), the defendant claimed ineffective assistance of counsel where he had chosen to proceed pro se with limited assistance provided by so- called "standby counsel."
The Court rejected the defendant's claim, quoting with approval the following language:
"'To prevail on a claim that counsel acting in an advisory or other limited capacity has rendered ineffective assistance, a self-represented defendant must show that counsel failed to perform competently within the limited scope of the duties assigned to or assumed by counsel.'" 189 W. Va. at 486, 432 S.E.2d at 756.