The following excerpt is from U.S. v. Barajas-Sanchez, 19 F.3d 1441 (9th Cir. 1994):
"As a general rule, we will not review challenges to the effectiveness of defense counsel on direct appeal. Such an issue is more appropriately reserved for habeas corpus proceedings, where facts outside the record, but necessary to the disposition of the claim, may be fully developed." United States v. Laughlin, 933 F.2d 786, 788 (9th Cir.1991) (citations omitted).
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