California, United States of America
The following excerpt is from People v. Lopez, F075992 (Cal. App. 2020):
As for appellant's second claim that initial counsel provided ineffective assistance by failing to move to suppress appellant's statements to law enforcement, appellant contends his statements were taken in violation of Miranda, and that initial counsel would have been successful in moving to suppress his statement. Respondent asserts the record is lacking to resolve the merits of such a claim. We agree with respondent's assessment. "[O]ur review on a direct appeal is limited to the appellate record." (People v. Barnett (1998) 17 Cal.4th 1044, 1183.) Stated another way, " 'Appellate jurisdiction is limited to the four corners of the record on appeal . . . .' " (People v. Waidla (2000) 22 Cal.4th 690, 743.) When a defendant's claim "is dependent upon evidence and matters not reflected in the record on appeal," we will not consider it on appeal. (People v. Barnett, supra, at p. 1183.)
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