Can a motion to reopen a case alleging ineffective assistance of counsel be reopened?

Indeed, as a practical matter, a motion to reopen is the only avenue ordinarily available to pursue ineffective assistance of counsel claims. In the criminal habeas context, this court has recognized that ineffective assistance of counsel claims "are ordinarily left for collateral habeas proceedings due to the lack of a sufficient evidentiary record as to `what counsel did, why it was done, and what, if any, prejudice resulted.'" United States v. Sager, 227 F.3d 1138, 1149 (9th Cir.2000) (quoting United States v. Quintero-Barraza, 78 F.3d 1344, 1347 (9th Cir.1995)). Similarly, when an alien alleges that former counsel was constitutionally ineffective, a motion to

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