involving those in active military service. Finally, all states provide a right to counsel by either statute, court decision, or court rule in at least some civil proceedings, with the most commonly covered proceedings being termination of parental rights, abuse/neglect, civil commitment, paternity, and civil contempt. The state court decisions can be based on interpretation of either the federal or state constitution, and under basic principles of federalism, a state court can grant more rights under its state constitution than the Supreme Court has recognized under the federal constitution. Conflict-free counsel Whether counsel is retained or appointed, the defendant has a right to counsel without a conflict of interest. If an actual conflict of interest is present, and that conflict results in any adverse effect on the representation, the result is automatic reversal. The general rule is that conflicts can be knowingly and intelligently waived, but some conflicts are unwaivable. Ineffective assistance of counsel In Strickland v. Washington (1984), the Court held that, on collateral review, a defendant may obtain relief if the defendant demonstrates both that defense counsel's performance fell below an objective standard of reasonableness (the "performance prong") and that, but for the deficient performance, there is a reasonable probability that the result of the proceeding would have been different (the "prejudice prong"). To satisfy the prejudice prong of Strickland, a defendant who pleads guilty must show that, but for counsel's deficient performance, they would not have pleaded guilty. In Padilla v. Kentucky (2010), the Court held that counsel's failure to inform an alien pleading guilty of the risk of deportation fell below the objective standard of the performance prong of Strickland and permitted an alien who would not have pleaded guilty but for such failure to withdraw his guilty plea. Pro se representation In Faretta v. California (1975), the court held that a criminal defendant has the right to knowingly and voluntarily opt for pro se representation at trial. This right is not per se violated by the appointment of standby counsel. There is no constitutional right to self-representation on appeal. Singapore The Constitution of Singapore mandates that "Where a person is arrested, he shall be informed as soon as may be of the grounds of his arrest and shall be allowed to consult and be defended by a legal practitioner of his choice." The Supreme Court of Singapore ruled that this means that the accused must