What is the test for ineffective representation of counsel in a personal injury case?

In most instances, claims of ineffective assistance of counsel are better addressed in collateral proceedings under 28 U.S.C. Sec. 2255. See United States v. Robinson, 967 F.2d 287, 290 (9th Cir.1992). However, we may review such claims on direct appeal if (1) the record is sufficiently developed to permit review and determination of the issue or (2) the legal representation is so inadequate that the defendant was obviously denied his Sixth Amendment right to counsel. Id.