In Massaro v. United States, 538 U.S. 500, 155 L. Ed. 2d 714, 123 S. Ct. 1690 (2003), the Supreme Court held that there is no procedural default for failure to raise an ineffective assistance of counsel claim on direct appeal. Id., at 1693. Among the reasons for preferring that these claims be brought in habeas proceedings, the Court said the trial record is not developed precisely for the purpose of preserving and litigating these claims. As a result, the Court said, the trial record is often incomplete and inadequate to resolve these claims. Id., at 1694. Even so, the Court did not hold that there claims must be brought in habeas proceedings. But the Supreme Court also said that cases exist in which "counsel's ineffectiveness is so apparent from the record that appellate counsel will consider it advisable to raise the issue on direct appeal." Id., at 1696. The Court even noted that there may be instances when an appellate Court will review it sua sponte. Ibid.