California, United States of America
The following excerpt is from People v. Medina, C069965 (Cal. App. 2015):
8. Actually, Giffard was correct that a claim of ineffective assistance of counsel is often more appropriately brought in a new trial motion or on a writ of habeas corpus than on direct appeal. (See People v. Pope, supra, 23 Cal.3d at pp. 426-427; People v. Fosselman, supra, 33 Cal.3d at pp. 582-583.)
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