Where ineffective assistance at trial isn't used to establish ineffective assistance on direct review, state habeas petition for ineffective assistance on direct review does not exhaust the ineffective assistance at trial for subsequent federal habeas review.
http://media.ca7.uscourts.gov/cgi-bin/rssExec.pl?Submit=Display&Path=Y2018/D08-17/C:15-3881:J:Wood:con:T:fnOp:N:2203949:S:0
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.