California, United States of America
The following excerpt is from People v. Barragan, B299822 (Cal. App. 2020):
appellate counsel who wish to raise the issue of inadequate trial representation should join a verified petition for writ of habeas corpus."' [Citations.] Because claims of ineffective assistance are often more appropriately litigated in a habeas corpus proceeding, the rules generally prohibiting raising an issue on habeas corpus that was, or could have been raised on appeal [citations] would not bar an ineffective assistance claim on habeas corpus." (People v. Mendoza Tello (1997) 15 Cal.4th 264, 266-267.)
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