California, United States of America
The following excerpt is from The People v. Spinella, E050823, No. RIF151949 (Cal. App. 2011):
3. Ineffective assistance of counsel claims based on matters outside the record on direct appeal are more appropriately raised in a habeas corpus proceeding. (People v. Mendoza Tello (1997) 15 Cal.4th 264, 266-267.)
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