Law Lessons from K.M. V. C.A.F., App. Div., A-0817-10T3, February 3, 2012:

A claim of ineffective assistance of counsel is not cognizable in the Domestic Violence setting, as this is a civil, not criminal, case. If it were cognizable, defendant would have to make a prima facie showing of ineffective assistance of counsel in accordance with the standards set forth in Strickland v. Washington, 466 U.S. 668, 687, 104 S. Ct. 2052, 2064, 80 L. Ed. 2d 674, 693 (1984).

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