California, United States of America
The following excerpt is from People v. Abraria, C088757 (Cal. App. 2020):
4. In a footnote, defendant alludes to possible ineffective assistance of counsel at sentencing. This is not a sufficiently developed argument stated under a separate heading or subheading, and therefore we do not consider it. (See Parisi v. Mazzaferro (2016) 5 Cal.App.5th 1219, 1226, fn. 10; Cal. Rules of Court, rule 8.204(a)(1)(B).) Our resolution of this appeal does not foreclose defendant from properly pursuing a claim of ineffective assistance of counsel in a petition for writ of habeas corpus in the trial court.
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