Counsel can argue that Teague does not apply to first-time claims of ineffective assistance of counsel. In most direct appeals, the record is not sufficient to raise the issue "my attorney did not give me immigration advice" because that requires testimony outside the record on direct appeal. If the Teague rule applies to first-time IAC claims, it is impossible for any court ever to announce a new rule/new development in the area of IAC claims, as such a claim could not be raised on direct appeal, and would be barred by Teague in a post-conviction IAC claim. Therefore, the Constitution does not permit Teague to bar such claims the first time they are made.