(A)  Law in Effect At Time of Error.  The reasonableness of counsel’s performance must be judged by the law in effect at the time of the alleged error.  Counsel does not render ineffective assistance in accurately advising a defendant under the law applicable at the time, which was later overruled.  Counsel “is expected . . . to possess knowledge of those plain and elementary principles of law which are commonly known by well informed attorneys, and to discover those additional rules of law which, although not commonly known, may readily be found by standard research techniques.”[115]

[115] Smith v. Lewis, 13 Cal.3d 349, 358 (1975).

Ninth Circuit

POST CON RELIEF - GROUNDS - INEFFECTIVE ASSISTANCE OF COUNSEL - PLEA NEGOTIATIONS - ERRONEOUS ADVICE TO REJECT PLEA BARGAIN BASED ON FAILURE TO RESEARCH THE LAW
Hoffman v. Arave, 455 F.3d 926 (9th Cir. 2006) (counsel ineffective by giving incompetent advice regarding prosecutions plea offer; counsel failed to be fully aware of state of the law in advising defendant whether to accept offer).

COUNSEL - INEFFECTIVE ASSISTANCE - MISADVICE
Sophanthvong v. Palmateer, ___ F.3d ___ (9th Cir. April 12, 2004) (Counsel not required to predict accurately how courts will resolve disputed issues; advice was at most "mere incorrect prediction" of application of statute and did not amount to "gross mischaracterization of the likely outcome" of plea bargain or trial; Strickland requires only objectively reasonable advice under prevailing professional norms).