The following excerpt is from U.S. v. Daniels, 54 F.3d 786 (9th Cir. 1995):
Finally, we do not consider appellants' claims that their attorneys were incompetent because the record on appeal is insufficient to allow review of the issue. See United States v. Robinson, 967 F.2d 287, 290 (9th Cir. 1992) (claims of ineffective counsel reviewed on direct appeal only where record is complete and counsel's representation is obviously inadequate).
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