What is the test for ineffective representation of a trial attorney?

Appellate review of a trial attorney's performance must be highly deferential. Consequently, "[u]nless a defendant establishes the contrary, we shall presume that 'counsel's performance fell within the wide range of professional competence and that counsel's actions and inactions can be explained as a matter of sound trial strategy.' [Citation.] If the record 'sheds no light on why counsel acted or failed to act in the manner challenged, ' an appellate claim of ineffective assistance of counsel must be rejected 'unless counsel was asked for an explanation and failed to provide one, or unless there simply could be no satisfactory explanation.'" (People v. Ledesma (2006) 39 Cal.4th 641, 745-746.) The appellate record seldom shows that there could be no rational explanation for an attorney's actions, and consequently, when the record is silent, the issue must be raised not on direct appeal, but on habeas corpus, which allows for an evidentiary hearing at which the reasons for the attorney's actions or omissions can be explored. (People v. Mendoza Tello (1997) 15 Cal.4th 264, 267.)¹⁴