How have the courts dealt with the forfeiture of a defendant's Miranda rights argument?

Miranda rights. Defendant forfeited this argument because he did not seek to suppress the statement on that basis below. (See People v. Scott (2011) 52 Cal.4th 452, 482; People v. Holt (1997) 15 Cal.4th 619, 667.) Defendant seeks to avoid forfeiture by arguing that his counsel was constitutionally ineffective by neglecting to raise this issue in the trial court. We conclude that counsel did not render deficient performance because no Miranda warnings were required.