Cited by

¶ 4 (2002) (“[W]here ineffective assistance of counsel claims are raised, or could have been raised, in a Rule 32 post-conviction relief proceeding, subsequent claims of ineffective assistance will be deemed waived and precluded.”) (emphasis omitted).

Generally, “where ineffective assistance of counsel claims are raised, or could have 4 STATE v. WEBER Decision of the Court been raised, in a Rule 32 post-conviction relief proceeding, subsequent claims of ineffective assistance will be deemed waived and precluded.” ¶ 4 (2002) (emphasis omitted); ¶ 21 (2024); --- ¶ 34 (2025) (“[W]hether a defendant must personally waive an IAC claim to warrant preclusion under Rule 32.2(a)(3) depends on the particular right implicated by the allegedly ineffectiv

The Arizona Supreme Court has held that “ineffective assistance of counsel claims are to be brought in [Arizona Rule of Criminal Procedure (“Rule”)] 32 proceedings.” ¶ 9 (2002).

¶ 9 (2002) (holding that ineffective assistance of counsel claims will not be addressed by appellate courts in a direct appeal).

¶ 9 (2002) (“[I]neffective assistance of counsel claims are to be brought in Rule 32 proceedings.

¶ 9 (2002) (“[W]e reiterate that ineffective assistance of counsel claims are to be brought in Rule 32 proceedings.

¶ 9 (2002) (finding that ineffective-assistance-of- counsel claims must be brought in a petition for post-conviction relief).

¶ 9 (2002) (finding that ineffective-assistance-of- counsel claims must be brought in a petition for post-conviction relief).

¶ 9 (2002) (explaining that “ineffective assistance of counsel claims are to be brought in Rule 32 proceedings,” and will not be addressed on direct appeal regardless of merit).

¶ 20 (2007) (“We therefore hold, consistent with [ ¶ 9 (2002)], that a defendant may bring ineffective assistance of counsel claims only in a Rule 32 post-conviction proceeding—not before trial, at trial, or on direct review.”).

Generally, “where ineffective assistance of counsel claims are raised, or could have been raised, in a Rule 32 post-conviction relief proceeding, subsequent claims of ineffective assistance will be deemed waived and precluded.” ¶ 4 (2002) (emphasis omitted).

P. 32; ¶ 9 (2002) (noting that ineffective assistance of counsel claims should be raised in Rule 32 proceedings).

P. 32.2(a)(2); ¶ 4 (2002) (“[W]here ineffective assistance of counsel claims are raised, or could have been raised, in a Rule 32 post-conviction relief proceeding, subsequent claims of ineffective assistance will be deemed waived and precluded.”) (Emphasis omitted.).

But “ineffective assistance of counsel claims are to be brought in Rule 32 proceedings,” and “will not be addressed by appellate courts [on direct appeal,] regardless of merit.” ¶ 9 (2002).