California, United States of America
The following excerpt is from People v. Millsap, B268402 (Cal. App. 2016):
assistance of counsel claim does not raise any arguable issues. (See, e.g., People v. Mendoza Tello (1997) 15 Cal.4th 264, 267 [where claims of ineffective assistance of counsel are based on matters that are outside the record on appeal, such claims are "often more appropriately litigated in a habeas corpus proceeding"].)
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