of counsel generally cannot be reviewed on direct appeal unless it has been presented to the district court.”); Fountain v. United States, 211 F.3d 429, 433-34 (7th Cir.2000)(ineffective assistance of counsel claims are not generally appropriate for direct appeal as they often rely on evidence outside the record); United States v. Kincaide, 145 F.3d 771, 785 (6th Cir.1998)(“Unless the record on appeal is adequate to assess the merits of the defendants' allegations, we will not address an ineffective assistance of counsel claim raised for the first time on direct appeal.”); United States v. Cocivera et al., 104 F.3d 566, 570 (3d Cir.1996) (same); United States v. Eltayib, 88 F.3d 157, 170 (2d Cir.1996) (same generally); United States v. Galloway, 56 F.3d 1239, 1241 (10th Cir. 1995) (<HOLDING>); United States v. Camacho, 40 F.3d 349, 355
holding that rule 322a is an adequate and independent procedural bar holding that a procedural rule that is not firmly established and regularly followed cannot bar federal court review recognizing general rule that ex post facto provision does not apply to purely procedural matters holding that the rule does not apply to bar tort claims against service providers holding that procedural bar rule does not apply to ineffectiveness claims