Right to challenge trial lawyers

1. Whether the Sixth Amendment and Due Process Clause allow a jurisdiction to (a) require that ineffective-assistance-of-trial-counsel claims be raised in a D.C. Code § 23-110 motion during the pendency of the direct appeal — thereby making appellate counsel effectively responsible for pursuing initial postconviction litigation — yet (b) later deny any merits forum for substantial trial-counsel ineffectiveness claims as procedurally defaulted when appellate counsel failed to do so. 2. Whether the District of Columbia may treat recall of mandate — an extraordinary and discretionary remedy subject to a strict 180-day deadline, D.C. App. R. 41(f) — as the exclusive mechanism to litigate ineffective assistance of appellate counsel as “cause” for failing to file a timely § 23-110 motion during the direct appeal, thereby leaving substantial Sixth Amendment claims without any merits forum. 3. Whether due process permits denial of an evidentiary hearing needed to resolve material, disputed facts supporting an ineffective-assistance claim — such as failure to present alibi testimony supported by sworn affidavits — when the lower courts’ procedural rulings otherwise foreclose any merits adjudication.