How have courts dealt with a claim of ineffective assistance of counsel?

^4. Respondent maintains appellant forfeited this argument by failing to raise the issue below. There is no need to reach the forfeiture issue as we resolve appellant's claim on the merits to forestall a claim of ineffective assistance of counsel. (See People v. Turner (1990) 50 Cal.3d 668, 708.)

^5. Appellant, in fact, admitted the Penal Code section 12022.1 enhancement allegation in this case that he was released on bail or on his own recognizance when he committed the present offenses, but the court did not impose the enhancement. The fact he was on bail or on his own recognizance when he committed the present offenses was a valid aggravating factor. (People v. Combs (1986) 184 Cal.App.3d 508, 511.)