California, United States of America
The following excerpt is from People v. Pope, 152 Cal.Rptr. 732, 23 Cal.3d 412 (Cal. 1979):
17 To promote judicial economy in direct appeals where the record contains no explanation, appellate counsel who wish to raise the issue of inadequate trial representation should join a verified petition for habeas corpus. (See, e. g., People v. Apodaca (1978) 76 Cal.App.3d 479, 489, fn. 3, 142 Cal.Rptr. 830.)
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