Can a defendant raise issues regarding defense counsel's representation by way of writ of habeas corpus?

We note that defendant may raise issues regarding defense counsel's representation by way of writ of habeas corpus. Claims of ineffective assistance of counsel are more appropriately litigated in a habeas corpus proceeding. The record before us sheds no light on the claims defendant raised in his request for certificate of probable cause. Where, as here, the record does not show why counsel acted or failed to act in the ways the defendant claims, we must reject an ineffective counsel claim based only on the record on appeal. (See People v. Mendoza Tello (1997) 15 Cal.4th 264, 266-267.) A verified petition for habeas corpus allows a defendant to allege facts outside the appellate record to show that counsel's failure was not justified by a tactical choice or

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