IAC on Direct Appeal (And "Fuck You, I Want to Talk to My Lawyer" is Not an Adoptive Admission).  This is something you don't see too much: earlier this month the California Court of Appeal (6th Dist.) reversed a conviction on the ground of ineffective representation. What's even more unusual, it was done on direct appeal. (People v. Lopez, no. H026476.) 

Here we will determine, among other things, that defense counsel should have objected to evidence that each of the four defense witnesses had been arrested and that three of them had committed misdemeanor batteries and that defendant’s invocation of his right to counsel, however colloquially phrased (“Fuck you. I want to talk to my lawyer”), should not have been construed as an adoptive admission.

California caselaw, like other jurisdictions, allows a court of appeal to find IAC on direct  appeal when there is no conceivable tactical reason for counsel's actions or where counsel's tactical reasons are apparent from the record. This case met that requirement: "The Attorney General suggests no tactical reason for defense counsel to withhold objection to evidence of mere arrests or misdemeanor conduct not involving moral turpitude, and we cannot imagine one."