The following excerpt is from United States v. Nunez, 19-37-cr (2nd Cir. 2020):
There is a preference for hearing claims for ineffective assistance of counsel at the trial level to allow the record to be fully developed. Massaro v. United States, 538 U.S. 500, 504-05 (2003). Thus, when a defendant makes an ineffective assistance of counsel claim on direct appeal, we have three options: "(1) decline to hear the claim, permitting the appellant to raise the issue as part of a subsequent petition for
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