Can a claim of ineffective assistance be raised in a motion for a new trial under Penal Code 4 section 1181?

A claim of ineffective assistance of counsel may be raised in a motion for new trial under Penal Code⁴ section 1181, even though it is not one of the statutorily enumerated grounds. (People v. Fosselman (1983) 33 Cal.3d 572, 582-583.) When the trial court has denied a motion for new trial based on an ineffective assistance claim, we apply the standard of review applicable to mixed questions of law and fact, upholding the trial court's factual findings to the extent they are supported by substantial evidence but reviewing de novo the ultimate question of whether the facts established demonstrate a violation of the right to effective counsel. (People v. Taylor (1984) 162 Cal.App.3d 720, 724-725.)