Ineffective assistance
Habeas for ineffective assistance on direct appeal that characterized an issue certain to require reversal as a substantial evidence challenge.
http://media.ca11.uscourts.gov/opinions/pub/files/201314995.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Not written by a barrister. The name was thought up by a second-year American law student sitting in a coffeehouse in Manhattan. Neither an authoritative statement of the law nor legal advice.
Don't rely. Quick work.