California, United States of America
The following excerpt is from People v. Jarquin, A148418 (Cal. App. 2018):
"When a claim of ineffective assistance is made on direct appeal, and the record does not show the reason for counsel's challenged actions or omissions, the conviction must be affirmed unless there could be no satisfactory explanation." (People v. Anderson (2001) 25 Cal.4th 543, 569.) Here, appellant argues there is no legitimate explanation or conceivable tactical reason for failing to object to the attorney fee.
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