What is the test for making a claim for ineffective assistance of counsel in a motion for habeas corpus?

^1. We note that certain types of claims must be raised and exhausted via state collateral proceedings. For example, because ineffective assistance of counsel claims often involve extra-record issues, California considers these claims to be "more appropriately made in . . . petition[s] for habeas corpus" and not on direct appeal. See People v. Pope, 590 P.2d 859, 867 (Cal. 1979) (en banc), abrogated in part on other grounds by People v. Ledesma, 729 P.2d 829, 868-69 (Cal. 1987) (en banc). But McMonagle need not file such a petition because he raises only claims that were already considered and rejected on direct review, which the California courts decline to reconsider in habeas proceedings. See In re Harris, 855 P.2d 391, 395-98 (Cal. 1993).