When will appellate counsel not be able to challenge a criminal conviction for ineffective assistance of counsel?

^7. Appellate counsel was also precluded from challenging petitioner's prior convictions in state court. Garcia v. Superior Court, 14 Cal.4th 953, 956 (1997) (A "criminal defendant may not challenge a prior conviction on the ground of ineffective assistance of counsel in the course of a current prosecution for a noncapital offense. Compelling a trial court in a current prosecution to adjudicate this type of challenge to a prior conviction generally would require the court to review the entirety of the record of the earlier criminal proceedings, as well as matters outside the record, imposing an intolerable burden upon the orderly administration of the criminal justice system.").