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In addition, appellate courts generally “will not review attacks on counsel’s trial strategy,” and “decisions about objections at trial are matters of trial strategy,” (quotation omitted).

d 414, 421 (Minn. 2004).

The “objective standard is defined as representation by an attorney exercising the customary skills and diligence that a reasonably competent attorney would 6 perform under similar circumstances.” (quotation omitted).

The “objective standard is defined as ‘representation by an attorney exercising the customary skills and diligence that a reasonably competent attorney would perform under similar circumstances.’” ().

“But we review the denial of postconviction relief based on a claim of ineffective assistance of counsel de novo because such claims involve mixed questions of law and facts.” Id.; (“Because claims of ineffective assistance of counsel involve mixed questions of law and fact, our review of decisions by the postconviction court is de novo.”).

Leake, d at 536 ; (noting that whether to call an expert witness and whether to cross-examine on a certain topic were matters of trial strategy); (holding that counsel’s decision to pursue certain evidence and not other evidence fell within the realm of defense strategy); (holding that appellant’s allegations that counsel failed to obtain expert testimony “involved the exercise of tactica

The Minnesota Supreme Court has “consistently considered witness recantation to be newly discovered evidence of false testimony and [has] therefore applied the Larrison test in such cases.” Tichich, d at 120; – 23 (Minn. 2004) (applying the Larrison standard to the appellant’s claim that several witnesses gave false testimony, which the appellant supported with affidavits in which three of the state’s witnesses recanted their testimony, as well as affidavits of individuals who claimed to have he

As in the context of appellate advocacy, however, “[w]e presume that trial counsel’s performance was reasonable and we give particular deference to trial strategy.” Schneider, d at 521; d 414, 421 (Minn. 2004).

We “will not review attacks on counsel’s trial strategy,” which includes “[t]he extent of counsel’s investigation.”

The supreme court has “noted that evidentiary hearings are particularly appropriate when the petition attacks important evidence in a circumstantial case.”

Reviewing courts “generally will not review attacks on counsel’s trial strategy.”

The “objective standard is defined as representation by an attorney exercising the customary skills and diligence that a reasonably competent attorney would perform under similar circumstances.” Opsahl v. State , (quotation omitted).

7, 1984); (“The extent of counsel’s investigation is considered a part of trial strategy.”).

421 (Minn. 2004) (declining to substantively address a petitioner’s failure-to-investigate- an-alternative-perpetrator claim because the decision was trial strategy).

In evaluating the first prong of the Strickland test, an appellate court generally “will not review an ineffective-assistance-of-counsel claim when the attorney’s conduct in question is based on trial strategy.” Chavez-Nelson, d at 671; (noting that appellate courts are poorly 10 placed to second- guess decisions of trial counsel).

(stating that extent of investigation and deciding which evidence to present is trial strategy).

Appellate courts usually do not “review attacks on counsel ’s trial strategy.” see also Nicks, d 9 at 50 8 (stating that matters of trial strategy are “virtually unchallengeable”).

transcripts of [his client]’s statements during its deliberations, were part of counsel’s [trial] strategy”); (counsel’s failure to call alibi witness was within counsel’s discretion as trial strategy to decide which witnesses to call and what evidence to present); (counsel’s decision to focus on other defenses instead of investigating alternative suspects and failure to present certain evidence were matters of trial strategy).

(noting that appellate courts are poorly placed to second - guess decisions of trial counsel).

(citing Larrison v. United States , 24 F.2d 82, 87-88 (7th Cir. 1928)).

(citing Larrison v. United States, 24 F.2d 82, 87-88 (7th Cir. 1928)).

“The extent of counsel’s investigation is considered a part of trial strategy[,]” and “[i]t is within trial counsel’s discretion to forgo investigation of leads not reasonably likely to produce favorable evidence,”

see Larrison, 24 F.2d at 87–88, overruled by United States v. Mitrione, 357 F.3d 712, 718 (7th Cir. 2004).

See, (victim later claimed she lied at trial); (witnesses to shooting made inconsistent statements); d 414, 423 (Minn. 2004) (several State fact witnesses described as a “chorus of liars” because of their recantations); Andersen, d at 172 (defendant’s mother gave trial testimony that was “self-contradictory” to her postconviction affidavit).

(noting that appellate courts are poorly placed to second guess decisions of trial counsel).