Whether state trial counsel rendered constitutionally ineffective assistance of counsel

QUESTION PRESENTED Q.(1): Whether state trial counsel rendered constitutionally ineffective , assistance of counsel when he failed to present evidence that the alleged crimes did not take place in the county charged in the information. The Petitioner proved, at a state evidentiary hearing, . that trial counsel’s performance was deficient and that the deficient performance prejudiced the defense in violation of the Sixth and Fourteenth Amendment of the United States Constitution. (2) Whether counsel was constitutionally deficient for failing to ensure that proper jury instructions were given and for failing to follow up with explaining the law and instructions, in violation of due process, the Fifth, Sixth, and Fourteenth Amendments of the United States Constitution , i