ANN WALSH BRADLEY, J.
¶ 1. The petitioner, Derryle S. McDowell, seeks review of a published decision of the court of appeals affirming a judgment of conviction and order denying postconviction relief.1 McDowell was convicted of robbery, kidnapping, and five counts of sexual assault while using a dangerous weapon, all as party to a crime. He contends that he was afforded ineffective assistance of trial counsel that was both deficient and prejudicial. Additionally, McDowell asserts that the circuit court erred in failing to permit him new counsel.
¶ 2. This case discusses the important issue of how criminal defense attorneys should deal with the prospect of client perjury. Specifically, it addresses under what circumstances counsel has knowledge of the perjury sufficient to trigger a requirement that a client testify in the unaided narrative rather than the usual [497]*497question and answer format.2 Prior to the decision of the court of appeals in this case, no Wisconsin case had defined what standard should be employed to determine when attorneys "know" their clients will lie.
¶ 3. We agree with the court of appeals that defense counsel may not substitute narrative questioning for the traditional question and answer format unless counsel knows that the client intends to testify falsely. Absent the most extraordinary circumstances, such knowledge must be based on the client's expressed admission of intent to testify untruthfully. We further determine that attorneys must advise the client, opposing counsel, and the circuit court of the change of questioning style prior to use of the narrative.
¶ 4. In the case before us, we conclude that defense counsel's performance was deficient in two respects: (1) he shifted to narrative questioning without advising his client beforehand; and (2) he used narrative questioning despite believing that his client intended to testify truthfully. We also conclude, however, that McDowell suffered no prejudice under the facts of this case. Finally, we reject McDowell's claim that the [498]*498circuit court erred in failing to permit him new counsel. Accordingly, we affirm the court of appeals.
I — I
¶ 5. On April 21,1997, an 18-year-old woman was sexually assaulted near a building at 4720 West Bur-leigh Street, Milwaukee. She had exited a bus and was followed by two men with guns. The men rushed her and forced her off the street. With guns to her head, they robbed her, fondled her, and repeatedly assaulted her sexually, penetrating her orally and vaginally by both penis and gun barrel. After the assaults, the victim spat ejaculate.
¶ 6. Although the victim could not identify her attackers, the State built its case based on evidence collected from her body, her clothing, and the scene. Police recovered a sample of the victim's saliva mixed with semen containing McDowell's DNA. They also recovered evidence containing the DNA of the second man, who eventually pled guilty.
¶ 7. McDowell was appointed counsel from the State Public Defender's Office. On the first day of trial, counsel informed the court that McDowell had fired him over the weekend. The exchange between the two was as follows:
[DEFENSE COUNSEL]: Judge, just so the Court is aware, I was fired over the weekend and that is where we stand.
THE COURT: He has no right to fire you. Only I can.
[DEFENSE COUNSEL]: I understand that. I am just advising the Court that Mr. McDowell has discontinued any efforts to assist, and that is where we are.
[499]*499THE COURT: Mr. McDowell, you have to understand something. [Defense counsel] is an officer of this Court. This matter has been scheduled for trial. This Court is the only one that has that authority to fire him, not you. If you decide you are not going to cooperate, well that is your own situation, but you don't have any rights to fire him. Only I do. And I am telling you on the weekend before trial he is not going to be fired by this Court.
This Court knows [defense counsel], knows his abilities, and he is staying on the case. [The] [c]ase is going to trial today. Understand it. You have a right to finality. So do the people of the State of Wisconsin. So do the victims in this case or alleged victims, and that is what is going to happen.
¶ 8. Later that day while discussing pre-trial motions, defense counsel informed the court that he did not know what the theory of defense would be because McDowell had become unassistive. Wary of another delay, the court indicated an intent to move forward with the case.3 It stated:
Well he must be unassistive long before this past weekend, so let's not get into that. That is hogwash. Let's go. The issue is long before this weekend with the amount of appearances we have had in this court on this case. If we don't have a theory of defense formulated and then whatever little iron[-]outs you have to do, that is different. That is an ongoing process anyway all during trial.
[500]*500¶ 9. The court then told McDowell that he could decide whether to cooperate with counsel. It explained, "Either you help or you don't help, and that is your decision. Obviously if you don't help[,] it obviously hurts your situation more than it helps it, but that is your call, not mine. Fair enough?" McDowell replied "Yes." Defense counsel later informed the court that he would reserve his opening statement until the close of the State's case.
¶ 10. On the third day of trial, after the State had rested, defense counsel expressed reservations to the court about his ability to effectively proceed as counsel. Although not specific, he implied that his concerns related to the possibility that McDowell would testify untruthfully. The court advised counsel that he had two options: (1) he could recommend to McDowell that he not testify if his intended account was untrue or so outrageous that a trier of fact would hold it against him; or (2) take the "middle ground" by calling McDowell to testify in narrative form.
¶ 11. While the court acknowledged a third option in counsel's motion to withdraw, it rejected that request because the resulting mistrial would affect "not only the rights of [McDowell] but the rights of all the other people" involved in the nearly completed jury trial. The court further reasoned that allowing counsel to withdraw would not necessarily accomplish anything since McDowell's next attorney would likely face the same ethical dilemma.
¶ 12. After a short break in which defense counsel conferred with McDowell, he informed the court that his client would be testifying truthfully. He declared:
Your honor, I have spoken with Mr. McDowell. Mr. McDowell advised me he does wish to testify and that what he would be testifying to will be the absolute truth [501]*501with respect to anything regarding this testimony. He wishes to get up there and testify as to the truth. ...
Judge I have no reason to believe in light of what Mr. McDowell has told me that he will not get up there and testify as to the truth. Therefore when he takes the stand I will be asking him questions, specific questions with respect to his testimony before this jury.
¶ 13. The court accepted counsel's decision. However, it warned him that "should something change," he should immediately advise the court and then proceed in the narrative form of questioning.
¶ 14. Defense counsel subsequently gave his opening statement. He told the jury that McDowell would testify that he never assaulted the victim and that the area where the crime took place was behind the building where his father lived. Counsel further explained that McDowell had been in the area the night before the assault, had oral sex with his girlfriend, Sunshine, and had ejaculated, which would account for the semen being found at the scene.
¶ 15. After completing his opening statement, defense counsel called McDowell to the witness stand. Shortly after McDowell took the stand, counsel received a note from the public defender’s office. Defense counsel began his examination in the conventional question and answer format and asked three questions about McDowell's age and residence. He then stated, "Mr. McDowell, I want you to look at this jury and tell this jury about the events of April 20 and April 21 of 1997. Take your time and speak loudly and clearly please." As McDowell began his answer, defense counsel interrupted and asked the court if it wanted a sidebar conference, and the court responded, "I certainly do."
¶ 16. Following an off-the-record discussion, the court instructed the jury that it was not to consider the [502]*502opening statements or closing arguments of counsel as evidence. It then directed defense counsel to restate the question. He said, "[a]gain, Mr. McDowell, take your time and tell this jury what you would like for them to know regarding the allegations against you beginning with where you were and what you were doing on April 20, 1997, through the early morning hours of April 21, 1997. Proceed please." The defendant responded with the following narrative answer:
On April 20, 1997, I was by my father's house at 4720 West Burleigh. Later on in the afternoon I had company. My girlfriend came over sometime in the afternoon. We watched TV We got movies and ate, joked around, played around. And as the evening went through we continued to watch movies, and I asked my father could I go to the gas station. He told me to take out the garbage before I went to the gas station so me and my girlfriend was cuddled up and I continued to ask did she want to go out in the back with me. And she first continued to tell me no, but afterward she told me yes. So I asked my father can I go to the gas station. He told me to take out the garbage.
Instead of me taking out the garbage, me and Sunshine, my girlfriend, had just went out the door to go to the gas station. That is where we were at. At the gas station we had two sodas and returned back to my father's apartment, 4720, but then we didn't go inside the apartment. We went outside around the back. While we was in the back we was fooling around and had oral sex in the back, and then by the time we had oral sex, after we were through and everything like that, my father ended up coming out in the back bringing out the garbage and caught me and my girlfriend fooling around back there and got yelling and screaming at me and my girlfriend telling us to go in the house. As we went to the house he told my girlfriend to call her mother, and he continued to yell and fuss and every[503]*503thing at ns. Her mother wasn't there, so he told her to get ready to take her home. Afterwards she got ready to go and continued fussing, continued to argue at us, and we took her home. And then we came back. First me and my father rode around because he continued to talk to me about what just happened back there, how dangerous it was and how we could have got in trouble and what we was doing was wrong. So we finally arrived back to my father's house. When we arrived we went in the house and went back to sleep.
That is what happened according to them days.
¶ 17. Defense counsel asked two more questions relating to McDowell's four juvenile adjudications. The prosecutor then conducted a brief cross-examination during which McDowell admitted that he had attempted to avoid arrest and run from the police. McDowell also revealed that he was a friend of the other man who had been convicted of the assaults. There was no re-direct examination.4
¶ 18. In his closing statement, defense counsel commented at length on the nature of DNA evidence. He then asked, "Where would you expect to find DNA material of yours? In your house? . . . Where else would you expect to find your DNA material but around where you in fact live or work or someplace that you fre[504]*504quent?" Counsel observed, "There is an expectation that you could find evidence of Mr. McDowell being related and associated with 4720 West Burleigh."
¶ 19. After the case was submitted to the jury, defense counsel provided an account of the off-the-record sidebar that had occurred when he shifted from question and answer to narrative form. He indicated that he had planned to proceed in the question and answer format. However, he acknowledged receiving a note from legal counsel at his office, which changed his mind. Counsel did note, however, that he had previously advised McDowell as to what a narrative entailed. He explained:
Subsequent to the initial decision to go ahead and do a question and answer with regards to Mr. [McDowell's] testimony, I did in fact receive an opinion back from Attorney Bill Tyroller [sic], who is both an appellate attorney as well as legal counsel for the agency, advising me that I should go with narrative. I did in fact advise Mr. Derryle McDowell that that is the way we would be proceeding, and we had already discussed what the narrative entailed prior to, as a result of prior discussions, so he was familiar with what it was that I was advising him that we were going to do in terms of his testimony. So that was the result of me making a switch from question and answer to the narrative.
¶ 20. During deliberations, the parties briefly reconvened to address a question from the jury: "Need to know time frame between sexual act with girlfriend and the time [the victim] was assaulted." The court stated that it intended to instruct the jury to use its collective memory relative to the time frame, if any, between the two acts. Neither the prosecutor nor defense counsel objected.
[505]*505¶ 21. Ultimately, the jury found McDowell guilty of all counts. He was sentenced to 40 years in prison, consecutive, on all five counts of first-degree sexual assault, followed by a consecutive probationary sentence on the two remaining counts. McDowell subsequently moved for postconviction relief, arguing, among other things, that his attorney had provided ineffective assistance of counsel and that the circuit court had erred in failing to permit him new counsel.
¶ 22. At the Machner5 hearing, defense counsel testified that he initially believed that McDowell and his girlfriend, Sunshine, had not engaged in any sexual activity behind the building the night before the assaults based on his pretrial discussion with them. He noted inconsistencies between their accounts.6 Moreover, he explained that McDowell had introduced the oral-sex-the-night-before theory of defense only after learning that any scientific challenge to the DNA evidence would be useless. Counsel ultimately decided not to call Sunshine as a witness.
¶ 23. In addition, defense counsel testified that McDowell had asked, "[']What if Sunshine and I get together and we say ...,[']" and had told him, "[']I'll say what I need [to] say to help myself out and if I have to say something untruthful I'll say that. I need to help myself out.[']". Counsel said that he warned McDowell [506]*506that he might have to testify in the narrative. In that situation, he advised McDowell to testify to everything he wanted the jury to hear because it would be his only opportunity.
¶ 24. Finally, defense counsel elaborated on the events leading to McDowell's actual testimony. He explained that he had intended to proceed in the question and answer format, as McDowell had eventually informed him that he was going to tell the truth. However, counsel acknowledged that his plan later changed when he received a note from the public defender's office, urging him to shift to the narrative. The note said, "Tyroler says go with a narrative. Tell that to the client. It must be narrative." Accordingly, defense counsel converted to the narrative form. He conceded, however, that he did so without either advising McDowell of the change beforehand or having concluded that McDowell intended to lie.
¶ 25. McDowell, meanwhile, testified at the hearing that he never told defense counsel he was going to testify untruthfully. He maintained that he was of the impression that counsel was going to employ the traditional question and answer format, not the narrative. Furthermore, McDowell stated that he had never testified before a jury before and was nervous and confused. He insisted that had he been asked, he would have testified that the night before the assaults Sunshine performed oral sex on him, that he was not wearing a condom, that he ejaculated at the scene, and that he never committed the crimes.
¶ 26. The circuit court denied McDowell's post-conviction motion. It noted that McDowell had placed defense counsel in an untenable position, and that counsel had reacted in a way that best preserved both his client's rights and his own ethical responsibilities. [507]*507The court further surmised that even with McDowell's full and complete testimony, the outcome of the trial would have been no different in light of the indisputable scientific evidence. Finally, it upheld the decision to proceed with existing counsel. The court explained, "with the jury literally in the wings, and the case ready to proceed, with the witnesses present and everybody having said they were ready to proceed, that that's a discretionary call by Judge Moroney, and he made that decision." McDowell appealed.
¶ 27. The court of appeals affirmed the circuit court. State v. McDowell, 2003 WI App 168, 266 Wis. 2d 599, 669 N.W.2d 204. In a thoughtful and scholarly opinion, it set forth the standard that it believed should govern a criminal defense attorney's legal obligations in assessing and responding to possible perjury. I'd., ¶ 3. The court stated that "absent the most extraordinary circumstances, criminal defense counsel, as a matter of law, cannot know that a client is going to testify falsely absent the client's admission óf the intent to do so." Id., ¶ 47.
¶ 28. Applying that standard to the case at hand, the court of appeals determined that defense counsel was deficient in his performance at trial. Id., ¶ 4. It also concluded, however, that the deficient performance was not prejudicial under the circumstances of the case. Id. Finally, the court rejected McDowell's claim that the circuit court erred in denying his request for new counsel. Id., ¶ 24. It reasoned that because the circuit court had received no request for new counsel, it could not have erred in failing to make such inquiry or determination. Id., ¶ 30.7
[508]*508r — i H-1
¶ 29. This case presents an opportunity to address how criminal defense attorneys should deal with the prospect of client perjury. The issue is raised in the context of the first argument in this case: ineffective assistance of counsel.
¶ 30. A claim of ineffective assistance of counsel invokes the analysis set forth in Strickland v. Washington, 466 U.S. 668 (1984). To find success, a defendant must demonstrate both (1) that counsel's representation was deficient; and (2) that this deficiency was prejudicial. Id. at 687.
¶ 31. Appellate review of an ineffective assistance of counsel claim is a mixed question of fact and law. State v. Erickson, 227 Wis. 2d 758, 768, 596 N.W.2d 749 (1999) (citing State ex rel. Flores v. State, 183 Wis. 2d 587, 609, 516 N.W.2d 362 (1994); State v. Pitsch, 124 Wis. 2d 628, 633-34, 369 N.W.2d 711 (1985)). We will not disturb the circuit court's findings of fact unless they are clearly erroneous. Id. at 768. The ultimate determination of whether the attorney's performance falls below the constitutional minimum, however, is a question of law subject to independent appellate review. Id. (citing Pitsch, 124 Wis. 2d at 634).
[509]*509¶ 32. Additionally, we consider whether the circuit court erred in failing to permit McDowell new counsel. A circuit court exercises discretion in determining whether to appoint new counsel in a criminal case. State v. Lomax, 146 Wis. 2d 356, 359, 432 N.W.2d 89 (1988). Accordingly, we review the decision of the circuit court to determine if it erroneously exercised its discretion.
Í — I HH HH
¶ 33. We begin our discussion with the threshold inquiry for evaluating McDowell's claim of ineffective assistance of counsel: Under what circumstances do criminal defense attorneys have knowledge of prospective perjury sufficient to trigger a requirement that a client testify in the unaided narrative rather than the usual question and answer format? Such a question implicates not only the constitutional rights of the criminal defendant, but also the ethical responsibilities of counsel.
¶ 34. The United States Supreme Court has not expressly set forth a standard of knowledge that, when met, requires a criminal defense attorney to reveal client confidences and affirmatively act to prevent client perjury. In Nix v. Whiteside, it observed that "[w]hatever the scope of a constitutional right to testify, it is elementary that such a right does not extend to testifying falsely." 475 U.S. 157, 173 (1986). The Court further recognized that, "[although counsel must take all reasonable lawful means to attain the objectives of the client, counsel is precluded from taking steps or in any way assisting the client in presenting false evidence or otherwise violating the law." Id. at 166. However, Nix [510]*510provided no guidance in determining when attorneys had sufficient basis to conclude that their clients intend to commit perjury.
¶ 35. Similarly, the Wisconsin rules of professional responsibility do not articulate a clear minimum standard of knowledge applicable to this case. Supreme Court Rule 20:3.3 (1999-2000)8 provides in relevant part:
Candor toward the tribunal.
(a) A lawyer shall not knowingly:
(1) make a false statement of fact or law to a tribunal;
(2) fail to disclose a fact to a tribunal when disclosure is necessary to avoid assisting a criminal or fraudulent act hy the client;
(4) offer evidence that the lawyer knows to be false. If a lawyer has offered material evidence and comes to know of its falsity, the lawyer shall take reasonable remedial measures.
Ob) The duties stated in paragraph (a) apply even if compliance requires disclosure of information otherwise protected by Rule 1.6 [regarding confidentiality of information received from a client].
(c) A lawyer may refuse to offer evidence that the lawyer reasonably believes is false.
(Emphasis added). Supreme Court Rule 20:3.4 provides in relevant part that "[a] lawyer shall not . . . falsify evidence, counsel or assist a witness to testify falsely[.]" (Emphasis added).
[511]*511¶ 36. The court of appeals reviewed Nix, the Supreme Court Rules, together with various legal authorities9 to discern the appropriate balance. McDowell, 266 Wis. 2d 599, ¶ 44. Under its standard, "absent the most extraordinary circumstances, criminal defense counsel, as a matter of law, cannot know that a client is going to testify falsely absent the client's admission of the intent to do so." Id., ¶ 47. The court explained that with its qualification of "extraordinary circumstances," it did not mean to obscure the bright line it created or invite endless litigation; rather, it simply recognized that in the truly exceptional case counsel might be presented with the same dilemma even absent a direct admission.10 Id., ¶ 48.
¶ 37. The court of appeals offered several justifications for its bright-line rule. To begin, it observed that adopting a lesser standard "would be a defining step in a sad parade" of situations (e.g., negotiated pleas [512]*512and Alford11 pleas) that, in its estimation, compromised a criminal defense attorney's duty to the client. Id., ¶ 44. Moreover, the court explained that without such an approach, counsel would lack guidance, as they cannot truly "know" whether the client intends to commit perjury. Id., ¶ 45. Finally, it suggested that the requirement of actual knowledge maximized the ability of criminal defense attorneys to protect their clients' Sixth Amendment rights. See id., ¶ 46.
¶ 38. Both McDowell and the amici12 support the court of appeals as to the standard it set regarding the issue of "knowledge."13 McDowell writes that, "[t]he decision appropriately balances defense counsel's duty to provide candor to the Court at all times along with his or her continuing duty to provide effective and competent assistance of counsel to the client." The amici, meanwhile, urge us to adopt the approach "because anything less jeopardizes the defendant's right to have a jury decide the facts, undermines the relation[513]*513ship and role of defense counsel as zealous and loyal advocate, and is practically unworkable."
¶ 39. The State, however, contends that the standard of the court of appeals demands too much. Specifically, it asserts that such an approach "will allow attorneys to dodge the ethical dilemma of prospective client perjury quite effectively by practicing selective ignorance of the only fact that would trigger their duty to prevent prospective perjury." The State submits that a different standard — one that takes into account all relevant facts and circumstances — will both protect the client's constitutional rights and better ensure the integrity of the criminal justice system. It therefore asks that we adopt the "firm factual basis" standard.
¶ 40. The difficulty we have with the State's position is twofold. First, the "firm factual basis" standard is really no standard at all. As noted by the amici in their brief, "[l]eaving it up to individual lawyers to 'take into account all relevant facts and circumstances' and decide whether a 'firm factual basis' exists to believe the client will commit perjury tells lawyers virtually nothing about when they should compromise their role as advocate." Such an approach, in our estimation, breeds needless uncertainty.14
[514]*514¶ 41. Second, we recognize that any standard we adopt should be a high one given the constitutional considerations involved. We are mindful that, "[ejxcept in the rarest of cases, attorneys who adopt 'the role of the judge or jury to determine the facts,' pose a danger of depriving their clients of the zealous advocacy and loyal advocacy required by the Sixth Amendment." Nix, 475 U.S. at 189 (Blackmun, J., concurring). As a result, we are reluctant to strip a defendant of the right to counsel or compromise the attorney-client relationship.
¶ 42. Thus, we are satisfied that the approach taken by the court of appeals was the appropriate one.15 Despite the multitude of standards, courts "generally have set an extremely high standard for" evaluating prospective perjury. Monroe H. Freedman, But Only If You "Know," in Ethical Problems Facing the Criminal Defense Lawyer 138 (Rodney J. Uphoff, 1995).
¶ 43. Accordingly, we determine that an attorney may not substitute narrative questioning for the traditional question and answer format unless counsel knows that the client intends to testify falsely. Absent the most extraordinary circumstances, such knowledge must be based on the client's expressed admission of intent to testify untruthfully. While we recognize that the defendant's admission need not be phrased in "magic words," it must be unambiguous and directly made to the attorney.
[515]*515¶ 44. We agree with the observation of the court of appeals that Supreme Court Rule 20:3.3 must be harmonized with our determination here. Like the court of appeals, we "interpret SCR 20:3.3(c)'s suggestion that counsel 'may refuse to offer evidence that the lawyer reasonably believes is false' to apply to circumstances beyond the borders surrounding the questions involving a criminal defendant's stated intention to testify falsely." McDowell, 266 Wis. 2d 599, ¶ 47. Indeed, "[a]ny other interpretation would, in our estimation, produce an irreconcilable conflict between the two rules." Id. (citing State v. Zielke, 137 Wis. 2d 39, 51, 403 N.W.2d 427 (1987)).
¶ 45. On those occasions when a defendant informs counsel of the intention to testify falsely, the attorney's first duty shall be "to attempt to dissuade the client from the unlawful course of conduct." Nix, 475 U.S. at 169. As the court of appeals noted, "we do not dismiss the persuasive power of counsel to do so on ethical, legal, and moral grounds." McDowell, 266 Wis. 2d 599, ¶ 53. Moreover, we recognize counsel's ability to be persuasive on pragmatic grounds. "By explaining what may be the evidentiary weakness of the false account, counsel can describe the likely consequences that, obviously, the defendant does not desire." Id.
¶ 46. In addition, we emphasize that an attorney should seriously consider moving to withdraw from the case.16 As noted by Nix, withdrawal "deprives the de[516]*516fendant of neither his right to counsel nor the right to testify truthfully." 475 U.S. at 173-74.
¶ 47. If, however, the motion to withdraw is denied and the defendant insists in committing perjury, we conclude that counsel should proceed with the narrative form, advising the defendant beforehand of what that would entail. While far from perfect, we recognize that the narrative represents the best of several imperfect options.17 It "best accommodates the competing interests of the defendant's constitutional right to testify and the attorney's ethical obligations." People v. Johnson, 62 Cal. App. 4th 608, 630, 72 Cal. Rptr. 2d 805 (1998).18
¶ 48. Finally, we agree with the court of appeals that attorneys must also inform opposing counsel and the circuit court of the change of questioning style prior [517]*517to use of the narrative. Courts, in turn, shall be required to examine both counsel and the defendant and make a record of the following: "(1) the basis for counsel's conclusion that the defendant intends to testify falsely; (2) the defendant's understanding of the right to testify, notwithstanding the intent to testify falsely; and (3) the defendant's, and counsel's, understanding of the nature and limitations of the narrative questioning that will result." McDowell, 266 Wis. 2d 599, ¶ 57.
IV
¶ 49. We turn next to McDowell's claim that he was afforded ineffective assistance of trial counsel. As noted above, in order to establish ineffective assistance, a defendant must prove that counsel's performance was both deficient and prejudicial. Strickland, 466 U.S. at 687. We consider each of these elements in turn.
¶ 50. To prove deficient performance, a defendant must establish that his or her counsel "made errors so serious that counsel was not functioning as the 'counsel' guaranteed the defendant by the Sixth Amendment." Id. Judicial scrutiny of counsel's performance will be highly deferential. Id. at 689. Deficient performance, nevertheless, may be demonstrated by acts and omissions "outside the wide range of professionally competent assistance." Id. at 690.
¶ 51. Here, McDowell contends that his trial counsel's actions were deficient in that he had no reason that justified a switch from the question and answer format to the narrative format. McDowell notes that defense counsel specifically told the court that his client would testify truthfully. Moreover, McDowell observes [518]*518that counsel did not change his mind regarding the presentation of the testimony until he was given the "Tyroler note." That note, McDowell reminds us, instructed counsel to "inform the client," which he did not do.
¶ 52. The State concedes that defense counsel rendered deficient performance at trial. Citing the reasoning of the court of appeals, it writes, "the State will not dispute the court's ultimate conclusion that [defense counsel] rendered deficient performance in requiring McDowell to testify in narrative format under the circumstances described above." The State, however, correctly notes that under Strickland it does not have to defend counsel's performance to prevail on appeal.
¶ 53. We agree with the parties that defense counsel's performance was deficient in this case. Although we are sympathetic to counsel's dilemma, we determine that his actions ultimately fell "outside the wide range of professionally competent assistance" in two respects. First, he shifted to narrative questioning without advising his client beforehand. Second, he used narrative questioning despite believing that his client intended to testify truthfully.
¶ 54. Accordingly, we address next whether defense counsel's deficiency prejudiced McDowell. Under Strickland, a defendant is not required to show that counsel's deficient conduct was outcome determinative. See id. at 693-94. Rather, "[t]he defendant must show that there is a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been different. A reasonable probability is a probability sufficient to undermine confi[519]*519dence in the outcome." Id. at 694. In making this determination, reviewing courts are to consider the totality of the evidence before the trier of fact. Id. at 695.
¶ 55. McDowell asserts that prejudice should be presumed under the circumstances of the case. He maintains that for all intents and purposes, he was without counsel at a critical stage of the proceeding when his attorney switched from question and answer to the narrative form. McDowell further submits that prejudice should be presumed because his attorney had a conflict of interest at the point in time he received the "Tyroler note."
¶ 56. Additionally, even if not presumed, McDowell advances that he suffered actual prejudice because he was not afforded the opportunity to fully present his defense to the jury. He contends that he had a plausible explanation for why his DNA was found at the scene, which was reconcilable with the remainder of the evidence. Because the jury never fully heard that explanation, McDowell reasons, his defense was prejudiced.
¶ 57. The State, meanwhile, asks that we affirm the conclusion of the court of appeals that McDowell suffered no prejudice. It argues that McDowell's case fits none of the limited circumstances in which this court presumes prejudices. Furthermore, it describes McDowell's theory of defense as both "implausible" and "improbable."
¶ 58. This court has made clear that it will presume prejudice only in rare instances. Erickson, 227 Wis. 2d at 770. In the limited category of cases most relevant to McDowell's claim, we have presumed prejudice when "the actual assistance rendered by a particu[520]*520lar attorney has been deemed so outside the bounds necessary for effective counsel that a court has presumed prejudice." Id. at 771.
¶ 59. For example, "courts have presumed prejudice when an attorney fails to present known evidence to the court calling into question the defendant's competency to stand trial." Id. (citing State v. [Oliver Ross] Johnson, 133 Wis. 2d 207, 223-34, 395 N.W.2d 176 (1986)). Likewise, "where an attorney has labored on behalf of a defendant while harboring a conflict of interest, prejudice is automatic." Id. (citing Cuyler v. Sullivan, 446 U.S. 335, 349-50 (1980); State v. Kaye, 106 Wis. 2d 1, 8-16, 315 N.W.3d 337 (1987)).
¶ 60. In the present case, we cannot conclude that defense counsel's action of switching from question and answer to the narrative form was "so outside the bounds necessary for effective counsel" as to constitute a rare instance when this court must presume prejudice. As the court of appeals correctly observed, "[defense counsel] was not absent and McDowell was not unrepresented during his testimony." McDowell, 266 Wis. 2d 599, ¶ 71, n. 23. Counsel further indicated that he had warned McDowell about the possible use of the narrative at trial and had advised him to testify to everything he wanted the jury to hear in that situation because it would be his only opportunity.
¶ 61. We also reject McDowell's claim that defense counsel had a conflict of interest that requires an automatic presumption of prejudice. Here, counsel's conflict stemmed from a perceived ethical dilemma between his duty of loyalty to his client and his ethical obligation to the court. This is not remotely the kind of conflict of interest at issue in Cuyler and Kaye. Cuyler [521]*521involved two attorneys' multiple representation of three defendants charged with murder. 446 U.S. at 337. Similarly, Kaye involved one attorney's representation of two defendants in the same arson case. 106 Wis. 2d at 3. To equate the divided loyalties in those cases with the potential divided loyalties here misses the mark. In every case, an attorney's loyalty to the client is tempered by the rules of professional responsibility. That divided loyalty, however, is not the type of conflict of interest that rises to the level of a presumption of prejudice.
¶ 62. Absent a presumption of prejudice, McDowell must make a showing of actual prejudice. Like the court of appeals, we "readily acknowledge that McDowell's testimony could have been enhanced and clarified through counsel's questioning." McDowell, 266 Wis. 2d 599, ¶ 66. It is true that McDowell's narrative account did not specify that Sunshine had performed oral sex on him, that he was not wearing a condom, or that he had ejaculated on the ground behind the building the day before the assaults. It is also true that McDowell did not actually deny that he had committed the assaults.
¶ 63. However, upon consideration of the totality of the evidence before the trier of fact, we are satisfied that McDowell suffered no actual prejudice in this case. When called upon to testify in the narrative form, McDowell produced an account of his actions during the period in question. That testimony included the date ("April 20,1997"), activity ("fooling around and had oral sex in the back"), and location ("4720 West Burleigh") that were critical to his "oral-sex-the-night-before" theory of defense. Such information, bracketed by de[522]*522fense counsel's opening statement and closing argument, provided a sufficient basis for the jury to reason its way to an acquittal if it so chose.19 Indeed, the question submitted by the jury indicates that McDowell's defense was on the mind of the jurors.
¶ 64. Our conclusion that McDowell suffered no prejudice is further supported by "two even more powerful reasons: his defense was preposterous, and the State's evidence was overwhelming." Id., ¶ 68. The court of appeals cogently explains:
McDowell's defense depended on his account of oral sex the night before with Sunshine at the very location where the assaults occurred. Not only was that theory far-fetched, but it was not going to be supported by any testimony from Sunshine, who, [defense counsel] concluded, should not testify given the inconsistencies between her and McDowell's accounts of their claimed encounter. But, of course, that's not all. McDowell's defense depended not only on the jury's acceptance of his oral-sex-the-night-before account, but also on the extraordinary coincidence of the victim's semen-filled saliva landing on the exact location of his ejaculate. It was not just that McDowell's DNA was discovered at the scene, but that his semen was mixed with the victim's saliva. As [defense counsel] testified at the Machner hearing, not only was McDowell's oral-sex-the-night-before defense a stretch, it was not, standing alone, exculpatory. [Counsel] was blunt: "The bottom line ... was . .. that mixed sample put his penis in her mouth."
Id., ¶ 69.
[523]*523¶ 65. In the end, we determine that defense counsel's deficiency was not so prejudicial that there is "a reasonable probability that, hut for counsel's unprofessional errors, the result of the proceeding would have been different." Indeed, the probability of selecting a person at random with the same DNA profile as McDowell in this case was approximately one in six billion. As a result, we reject McDowell's claim of ineffective assistance of counsel.
V
¶ 66. The final issue we consider is whether the circuit court erred in failing to permit McDowell new counsel. In situations involving appointment of new counsel, a circuit court's exercise of discretion is triggered by a defendant's presentation of a substantial complaint that could be interpreted as a request for new counsel. State v. Kazee, 146 Wis. 2d 366, 371, 432 N.W.2d 93 (1988). When a substantial complaint is made, the trial judge should inquire whether there are proper reasons for substitution. Id. (citations omitted).
¶ 67. Here, there is no dispute that on the morning of the first day of trial, defense counsel advised the court that McDowell had "fired" him over the weekend. There is also no dispute, however, that neither counsel nor McDowell explained why. Accordingly, the question becomes whether the circuit court erroneously exercised its discretion by failing to inquire into the matter before ruling that McDowell could not have new counsel.
¶ 68. McDowell contends that defense counsel's disclosure on the first day of trial was tantamount to a request for new counsel. Although he acknowledges [524]*524that counsel's request was not specific, McDowell maintains that, "[i]t should have been obvious to all those involved that counsel was no longer wanted as McDowell's attorney." McDowell further submits that the conflict which arose between counsel and client before trial was "too wide a divide to permit meaningful representation."
¶ 69. The State responds that the court of appeals correctly concluded that McDowell did not make a substantial complaint that could reasonably be interpreted as a request for new counsel. Alternatively, it argues that the circuit court did not err in refusing to permit counsel to withdraw based on the facts of the case.
¶ 70. Upon examining the record, we note that defense counsel did not actually move to withdraw on the first day of trial, even though he acknowledged being "fired." Moreover, we recognize that McDowell himself made no request for new counsel, even though he spoke to the circuit court, confirming his understanding that he would benefit by cooperating with his attorney.
¶ 71. Still, like the court of appeals, we "do not endorse the trial court's quick 'hogwash' reaction. A defendant's right to representation must be protected and, even absent an explicit request for new counsel, courts should inquire into what they may reasonably infer is a problem potentially undermining that right." McDowell, 266 Wis. 2d 599, ¶ 27, n. 10.
[525]*525¶ 72. Thus, we employ the factors set forth in State v. Lomax to determine whether withdrawal of counsel and the appointment of new counsel was warranted under the circumstances of this case. These include:
(1) the adequacy of the court's inquiry into the defendant's complaint; (2) the timeliness of the motion; and (3) whether the alleged conflict between the defendant and the attorney was so great that it likely resulted in a total lack of communication that prevented an adequate defense and frustrated a fair presentation of the case.
Lomax, 146 Wis. 2d at 359 (citations omitted).
¶ 73. In addressing the first Lomax factor, we acknowledge that the circuit court did not conduct a colloquy to more fully develop the substance of McDowell's complaint. However, as the State notes, this must be set against "the fact that neither [defense counsel] nor McDowell offered any evidence of incompetency or of a conflict that made counsel's continued representation untenable." In light of the record, we agree that the circuit court cannot reasonably be faulted for failing to make a full inquiry.
¶ 74. The second Lomax factor supports upholding the circuit court's decision. We have previously noted that "defendants in criminal cases often attempt to secure last-minute substitution of counsel to delay the trial, and the practice has 'plagued' the criminal courts in Milwaukee county." Kazee, 146 Wis. 2d at 373. Given the number of adjournments in this case, along with the lack of clear expression on the part of both [526]*526defense counsel and McDowell, it is understandable why the circuit court rejected McDowell's eleventh-hour attempt to fire counsel.
¶ 75. Finally, the third Lomax factor also favors the circuit court. The record does not support that the alleged conflict between McDowell and defense counsel was so great that it resulted in a total lack of communication, or prevented an adequate defense. Indeed, as the State observes, it seems likely that the court's remarks to McDowell regarding the advisability of cooperating with counsel persuaded him to communicate with counsel. The fact that McDowell disagreed with his attorney over the presentation of his testimony does not, in our view, automatically create "an irreconcilable conflict which leads to an apparently unjust verdict." State v. Wanta, 224 Wis. 2d 679, 703, 592 N.W.2d 645 (Ct. App. 1999).
¶ 76. Based on these factors, we cannot conclude that the circuit court erroneously exercised its discretion in denying McDowell new counsel. Accordingly, we reject his claim.
VI
¶ 77. In sum, we agree with the court of appeals that defense counsel may not substitute narrative questioning for the traditional question.and answer format unless counsel knows that the client intends to testify falsely. Absent the most extraordinary circumstances, such knowledge must be based on the client's expressed admission of intent to testify untruthfully. We further determine that attorneys must advise the client, opposing counsel, and the circuit court of the change of questioning style prior to use of the narrative.
[527]*527¶ 78. In the case before us, we conclude that defense counsel's performance was deficient in two respects: (1) he shifted to narrative questioning without advising his client beforehand; and (2) he used narrative questioning despite believing that his client intended to testify truthfully. We also conclude, however, that McDowell suffered no prejudice under the facts of this case. Finally, we reject McDowell's claim that the circuit court erred in failing to permit him new counsel. Accordingly, we affirm the court of appeals.
By the Court. — The decision of the court of appeals is affirmed.
¶ 79. DIANE S. SYKES, J. did not participate.