Calene v. State
In Calene v. State, 846 P.2d 679, 692-93 (Wyo. 1993), Justice Urbigkit described these varying situations and the need for a remand to the trial court when the ineffectiveness claim requires development of the record.
The purpose of the remand is not solely to adduce evidence; rather, the trial court "will provide a specific decision addressing separate contentions by examination and resolution of the validity of any trial court ineffectiveness of counsel contentions." Id. at 692.