Ineffective assistance claims must be firmly founded in the record, and the record must affirmatively show the alleged ineffectiveness. In re L.C.W., 411 S.W.3d 116, 127 (Tex. App.—El Paso 2013, no pet.) (citations omitted); see also Walker v. Tex. Dep't of Family & Protective Servs., 312 S.W.3d 608, 622-23 (Tex. App.—Houston [1st Dist.] 2009, pet. denied) (citations omitted).

"[I]neffective assistance claims must be firmly found in the record, and the record must affirmatively show the alleged ineffectiveness. In re L.C.W., 411 S.W.3d 116, 127 (Tex. App.—El Paso 2013, no pet.); see also Walker v. Tex. Dep't of Family & Protective Servs., 312 S.W.3d 608, 622-23 (Tex. App.—Houston [1st Dist.] 2009, pet. denied). When the record is silent concerning the reasons for counsel's actions, the reviewing court will not engage in speculation to find ineffective assistance of counsel, and the appellant bears the burden of overcoming the presumption that, under the circumstances, the challenged conduct might be considered sound trial strategy.

Accordingly, ineffective assistance of counsel claims must be firmly founded in the record, and the record must affirmatively show the alleged ineffectiveness. In re D.H.G., No. 04-21-00183-CV, 2021 WL 5088738, at *3 (Tex. App.-San Antonio Nov. 3, 2021, pet. denied); In re L.C.W., 411 S.W.3d 116, 127 (Tex. App.-El Paso 2013, no pet.).

Ineffective assistance of counsel claims must be firmly founded in the record. In re L.C.W., 411 S.W.3d 116, 127 (Tex. App.-El Paso 2013, no pet.); see also Walker v. Tex. Dep't of Family &Protective Servs., 312 S.W.3d 608, 622-23 (Tex. App.-Houston [1st Dist.] 2009, pet. denied). When the record is silent concerning the reasons for counsel's actions, the reviewing court may not speculate to find the representation ineffective.

If the record is silent regarding the reasons for counsel's actions, we do not engage in speculation to find ineffective assistance. In re L.C.W., 411 S.W.3d 116, 127 (Tex. App.—El Paso 2013, no pet.). We find ineffective assistance only if the conduct is "so outrageous that no competent attorney would have engaged in it."

Ineffective assistance claims must be firmly founded in the record, and the record must affirmatively show the alleged ineffectiveness. In re L.C.W., 411 S.W.3d 116, 127 (Tex. App.-El Paso 2013, no pet.); see also Walker v. Tex. Dep't of Family & Protective Servs., 312 S.W.3d 608, 622-23 (Tex. App.-Houston [1st Dist.] 2009, pet. denied). When the record is silent concerning the reasons for counsel's actions, the reviewing court will not engage in speculation to find ineffective assistance of counsel, and the appellant bears the burden of overcoming the presumption that, under the circumstances, the challenged conduct might be considered sound trial strategy.

Even constitutional issues must be properly raised in the trial court, or they are forfeited on appeal. In re L.C.W., 411 S.W.3d 116, 124-25 (Tex. App.—El Paso 2013, no pet.); Holcombe v. Reeves Cty. Appraisal Dist., 310 S.W.3d 86, 90 (Tex. App.—El Paso 2010, no pet.); In re Baby Boy R., 191 S.W.3d 916, 921-22 (Tex. App.—Dallas, pet. denied), cert. denied, Gidney v. Little Flower Adoptions, 549 U.S. 1080 (2006).

Ineffective assistance claims must be firmly founded in the record, and the record must affirmatively show the alleged ineffectiveness. In re L.C.W., 411 S.W.3d 116, 127 (Tex. App.—El Paso 2013, no pet.); see also Walker v. Tex. Dep't of Family & Protective Servs., 312 S.W.3d 608, 622-23 (Tex. App.—Houston [1st Dist.] 2009, pet. denied). When the record is silent concerning the reasons for counsel's actions, the reviewing court will not engage in speculation to find ineffective assistance of counsel, and the appellant bears the burden of overcoming the presumption that, under the circumstances, the challenged conduct might be considered sound trial strategy.

Ineffective assistance claims must be firmly founded in the record, and the record must affirmatively show the alleged ineffectiveness. In re L.C.W., 411 S.W.3d 116, 127 (Tex. App.—El Paso 2013, no pet.); see also Walker v. Tex. Dep't of RI Family & Protective Servs., 312 S.W.3d 608, 622-23 (Tex. App.—Houston [1st Dist.] 2009, pet. denied). When the record is silent concerning the reasons for counsel's actions, the reviewing court will not engage in speculation to find ineffective assistance of counsel, and the appellant bears the burden of overcoming the presumption that, under the circumstances, the challenged conduct might be considered sound trial strategy.

Ineffective assistance claims must be firmly founded in the record, and the record must affirmatively show the alleged ineffectiveness. In re L.C.W., 411 S.W.3d 116, 127 (Tex. App.—El Paso 2013, no pet.); see also Walker v. Tex. Dep't of Family & Protective Servs., 312 S.W.3d 608, 622-23 (Tex. App.—Houston [1st Dist.] 2009, pet. denied). When the record is silent concerning the reasons for counsel's actions, the reviewing court will not engage in speculation to find ineffective assistance of counsel, and the appellant bears the burden of overcoming the presumption that, under the circumstances, the challenged conduct might be considered sound trial strategy.