In re Children of Shennevia Y.

Summary

The court affirmed the termination of the mother's parental rights, holding that her direct-appeal ineffective-assistance claim had to be evaluated solely on the existing trial record and that the record did not establish a prima facie case of deficient performance or prejudice. The court also declined to consider affidavits containing information outside the trial record. Counsel's decisions to focus on the mother's treatment efforts and to advocate for relatives as potential permanency guardians were reasonable strategies supported by the record.