When will a defendant bring a claim of ineffective assistance of counsel to the Court of Appeal?

In claims of ineffective assistance of counsel, our review is limited to the appellate record, and we presume defense counsel acted within the wide range of reasonable professional assistance when making a tactical decision. (See People v. Mai (2013) 57 Cal.4th 986, 1009.) Because rebutting this presumption typically requires evidence outside the record, claims of ineffective assistance of counsel generally are raised in habeas corpus proceedings, a process that allows for an evidentiary hearing. (People v. Carrasco (2014) 59 Cal.4th 924, 980-981.) Consequently, appellate courts commonly decline to decide an ineffective assistance of counsel claim. If, however, a defendant possesses or can obtain evidence that is not in the appellate record, he or she may present the claim by way of a petition for writ of habeas corpus. (See People v. Williams (2013) 56 Cal.4th 630, 691 [some ineffective assistance claims "can be fully addressed only in a habeas corpus petition because they require investigation of evidence outside the record

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in order to potentially establish prejudice"]; People v. Barella (1999) 20 Cal.4th 261, 272 [defendant's claim of ineffective assistance of counsel should be resolved in a habeas corpus proceeding rather than on appeal].)