What is the test for determining whether a defendant has ineffective counsel?

Span first argues that his trial counsel was ineffective. Because claims of ineffective assistance require a careful examination of the record, they are usually handled by way of collateral challenge under 28 U.S.C. Sec. 2255 rather than on direct review. See United States v. Davis, 15 F.3d 902, 911 (9th Cir.1994) (as amended). While it is true that "we may review such claims on direct appeal if (1) the record is sufficiently developed to permit review and determination of the issue or (2) the legal representation is so inadequate that the defendant was obviously denied his Sixth Amendment right to counsel[,]" id., we hold that the question presented in the instant appeal is more appropriate for collateral review after a fuller development of the record. Accordingly, we decline to reach the merits of this issue.