What are the reasons why defense counsel opted not to object during the prosecution's rebuttal argument?

On direct appeal, however, we do not know what defense counsel's actual reasons were for opting not to object during the prosecution's rebuttal argument. Because I believe it is possible (I reserve judgment on whether it is likely) that the absence of an objection could have been a reasonable tactical choice, I agree defendant's ineffective assistance of counsel argument does not carry the day. Precedent makes clear that such claims are better resolved on habeas review, where presumably there would be a fuller record of the reasons for counsel's actions (or omissions). (People v. Mendoza Tello, supra, 15 Cal.4th at p. 267 ["[C]laims of ineffective assistance are often more appropriately litigated in a habeas corpus proceeding"].) Should we again confront the issue in a habeas proceeding with a more developed record, the

Page 36

"particularly difficult" standard of review that now applies will apply no longer.