Does the forfeiture rule apply to an order requiring defense counsel to provide additional discovery at trial?

Defense counsel did not object to the court's order, thereby forfeiting the issue for the purposes of appeal. (See People v. McCullough (2013) 56 Cal.4th 589, 593.) However, defendant argues the forfeiture rule should not apply, because the court's order was structural error requiring reversal per se. He asserts the order amounted to constructive denial of his Sixth Amendment right to counsel at a critical stage, because it imposed a duty to provide additional discovery that prevented his counsel from effectively cross-examining witnesses.

We are not persuaded that the court's order was structural error, because it did not limit the scope of cross-examination or defense counsel's ability to cross-examine the witnesses. The court merely restricted the manner in which impeachment evidence would be presented at trial. (See People v. Smith (2007) 40 Cal.4th 483, 513.) As the order did not constructively deny defendant of his right to counsel at a critical stage, any alleged error was not structural.