Is ineffective assistance of trial counsel appropriate for direct review?

But also, and the dispositive factor here, claims of ineffective assistance of trial counsel are very seldom appropriate for direct review. United States v. Steele, 733 F.3d 894, 897 (9^th Cir. 2013). This is so because why counsel did what he did, the determinative factor in assessing counsel's reasonableness, is nearly always a matter outside the record. Unless the record is fully developed on the matter of "why," or the conduct is so patently unreasonable on its face, can an appellate court on direct review make such an assessment. Id.