Does a defendant have a burden of proving that counsel's representation was deficient or ineffective on appeal?

Defendant does not carry his burden of affirmatively showing that counsel's representation was deficient. "When a claim of ineffective assistance is made on direct appeal, and the record does not show the reason for counsel's challenged actions or omissions, the conviction must be affirmed unless there could be no satisfactory explanation." (People v. Anderson (2001) 25 Cal.4th 543, 569.) Here, there may well have been sound strategic reasons for counsel's decision not to call an expert. Defense counsel himself exposed inconsistencies in the eyewitnesses' testimony and, as defendant's brief describes it, "zealously cross-examined both eyewitness victims." Defense counsel also argued that the eyewitnesses' testimony was not credible, and he attacked eyewitness testimony generally as "one of the weakest, most unreliable bits of evidence that we put in Court here . . . ." Counsel relied on the exhaustive list of factors identified in CALCRIM No. 315 that affect the reliability of eyewitness identification testimonyincluding the eyewitness being under stress, lighting, and cross-racial identificationto argue that the eyewitness testimony should be disbelieved. Counsel could have concluded that these factors were within the jury's common understanding and that he could effectively argue his case without expert testimony.