California, United States of America
The following excerpt is from People v. Bautista, F066370 (Cal. App. 2014):
Conceivably, further questioning could have provided answers to these questions that would have constituted compelling evidence supporting appellant's defense. However, as the court stated in People v. Medina (1995) 11 Cal.4th, 694, 773: "On direct appeal, a claim of ineffective counsel cannot be established by mere speculation
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