California, United States of America
The following excerpt is from People v. Correa, H041685 (Cal. App. 2016):
5. Defendant's claim of ineffective assistance of counsel is therefore based in part on matters that are outside of the appellate record. " ' "[If] the record on appeal sheds no light on why counsel acted or failed to act in the manner challenged . . . ," the claim on appeal must be rejected.' " (People v. Mendoza Tello (1997) 15 Cal.4th 264, 266.) "A claim of ineffective assistance in such a case is more appropriately decided in a habeas corpus proceeding." (Id. at pp. 266-267.)
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