Accordingly, a federal convict's failure to raise an ineffective-assistance claim on direct appeal to a federal court of appeals does not waive or procedurally default the claim. See Eason v. US, 2008 WL 4777480, *2 (W.D. Mich. Oct. 30, 2008) (Bell, J.) (citing Massaro v. US, 538 U.S. 500, 504 (2003)). As the Supreme Court has cautioned, "`judicial scrutiny of counsel's performance must be highly deferential. . . . Because of the difficulties inherent in making the evaluation, a court must indulge a strong presumption that counsel's conduct falls within the wide range of reasonable professional assistance.'"