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¶ 14 (App. 2000) (“[O]nce the State engages in plea bargaining, the defendant has a Sixth Amendment right to be adequately informed of the consequences before deciding whether to accept or reject the offer.”).

¶9 At the outset, the State contends that we need not address Emedi’s arguments concerning Rule 17.4(a)(2) ¶ 46 (App. 2000), not a settlement conference.

¶ 14 (App. 2000) 1 We view the evidence in the light most favorable to sustaining the convictions and resolve all reasonable inferences against Agyepong.

¶ 21 (App. 2000) (to warrant an evidentiary hearing, a Rule 32 claim “must consist of more than conclusory assertions”); ¶ 16 (App. 2013) (insufficient argument waives claim on review); ¶ 9 (App. 2000) (summarily rejecting cl

rovide specific factual allegations, not just conclusory assertions, to show that counsel “(1) gave erroneous advice or (2) failed to give information necessary to allow the petitioner to make 2 STATE v. GRANADO Decision of the Court an informed decision whether to accept the plea.” ¶¶ 16–17 (App. 2000).

The court held a hearing regarding the State’s and Fender ultimately rejected the offer.

4 STATE v. ESTLING Decision of the Court “[p]roof of ineffectiveness must be a demonstrable reality rather than a matter of speculation”); ¶ 21 (App. 2000) (to warrant evidentiary hearing, PCR claim “must consist of more than conclusory assertions”).

ATE v. CALVILLO Decision of the Court ¶9 Petitioner cannot show that counsel’s performance was deficient during plea negotiations, Runningeagle, 176 Ariz. at 63, meaning that counsel “either (1) gave erroneous advice or (2) failed to give information necessary to allow the petitioner to make an informed decision whether to accept the plea.” ¶ 16 (App. 2000).

P. 33.16(c)(2); ¶ 21 (App. 2000) (to warrant evidentiary hearing, Rule 32 claims “must consist of more than conclusory assertions”).

To determine whether the invited error doctrine should preclude a party from raising an allegation of error on appeal, courts “must look ‘to the source of the error, which must be the party urging the error.’” ¶ 17 (App. 2009) (quoting Logan, 200 Ariz. at 566, ¶ 11); see also Escalante, 245 Ariz. at 145, 4 ¶ 46 (App. 2000).

¶ 17 (App. 2000) (observing that a colorable ineffective assistance claim requires the defendant to “present more than a conclusory assertion”).

¶ 17 (App. 3 STATE v. PALAZZETTI Decision of the Court 2000) (observing that defendants “must provide specific factual allegations,” and not merely “conclusory assertion[s],” to warrant an evidentiary hearing on an

DISCUSSION ¶4 De Groote raises the following six issues: (1) whether he was competent to waive counsel during the 2015 proceeding in which the court imposed probation; (2) whether his mental state when he accepted the State’s plea offer negated notice of his probationary conditions; (3) before he accepted the plea offer; (4) whether the court violated De Groote’s right to counsel by granting his request to represent himself at the revocation hearing; (5) whether the court 2 STATE v. DE GROOTE D

¶11 “To establish deficient performance during plea negotiations, a petitioner must prove that the lawyer either (1) gave erroneous advice or (2) failed to give information necessary to allow the petitioner to make an informed decision whether to accept the plea.” ¶ 16 (App. 2000).

¶8 ¶ 46 (App. 2000), this court held that a defendant "suffers a constitutionally significant injury" when the defendant "loses a favorable plea bargain as a consequence of ineffective assistance of counsel."

Defense counsel need do no more than inform Santistevan of the outcome of this appeal and his future options, unless, upon review, counsel finds “an issue 2

¶3 The State extended at least one plea offer to Quiroz, which expired given the passage of time without being accepted