The California Supreme Court in Garcia v. Superior Court (1997) 14 Cal.4th 953 held that "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." ( Id., at p. 956.) The Garcia court expressed concern for the potential disruption to the administration of criminal justice if defendants were afforded the right to collaterally attack prior convictions based upon claims of ineffective assistance of counsel. ( Id., at p. 966.) Such claims would require reviewing courts to examine "the entirety of the record of the earlier criminal proceedings, as well as matters outside the record . . . ." ( Id., at p. 956.) The Garcia court referred to three policy reasons for generally refusing to allow belated attacks on prior convictions: avoidance of delay, ease of judicial administration, and promotion of the finality of judgments. ( Id., at pp. 961-962.)