Does ineffective assistance have to be addressed on appeal than in a habeas corpus proceeding?

There are practical constraints that make it more difficult to address ineffective assistance claims on direct appeal as opposed to a habeas corpus proceeding. (People v. Mickel (2016) 2 Cal.5th 181, 198.) First, "[t]he record on appeal may not explain why counsel chose to act as he or she did. Under those circumstances, a reviewing court has no basis on which to determine whether counsel had a legitimate reason for making a particular decision, or whether counsel's actions or failure to take certain actions were objectively unreasonable." (Ibid.)