California, United States of America
The following excerpt is from People v. Cabrera, A156395 (Cal. App. 2020):
On direct appeal where the record does not disclose the reason for counsel's actions, we may reverse " 'only if (1) the record affirmatively discloses counsel had no rational tactical purpose for the challenged act or omission, (2) counsel was asked for a reason and failed to provide one, or (3) there simply could be no satisfactory explanation.' [Citations.]" (People v. Arredondo (2019) 8 Cal.5th 694, 711.)
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