Is ineffective assistance an ineffective assistance claim?

In Billy-Eko v. United States, 8 F.3d 111 (2d Cir.1993), we carved out a special exception for ineffective assistance claims raised in a 2255 motion. We recognized that since many defendants are represented by the same attorney at trial and on direct appeal, it would be unrealistic to expect that attorney to identify and attempt to persuade an appellate court that he/she had committed

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