What is the test for a claim of ineffective assistance on appeal?

"[C]laims of error in the trial court's exercise of its sentencing discretion are . . . forfeited if not raised at the sentencing hearing." (People v. Trujillo (2015) 60 Cal.4th 850, 856.) By contrast, "[a] claim that a sentence is unauthorized may be raised for the first time on appeal . . . . [Citation.]" (People v. Barnwell (2007) 41 Cal.4th 1038, 1048, fn. 7.) Here, consecutive sentences were not unauthorized. This is not a case in which the trial court could not have imposed consecutive sentences under any circumstances. Rather, defendant's contention is that it imposed consecutive sentences based on a misapprehension regarding the applicable legal standard. That would be an abuse of discretion (see People v. Knoller (2007) 41 Cal.4th 139, 156 ["an abuse of discretion arises if the trial court based its decision . . . on an incorrect legal standard"]), but it would not result in an unauthorized sentence. Accordingly, defense counsel's failure to raise the issue below did work a forfeiture.

We therefore consider whether this forfeiture constituted ineffective assistance. "In order to establish a claim of constitutionally deficient performance by counsel, defendant must establish that (1) counsel's representation fell below an objective standard of reasonableness under prevailing professional norms; and (2) there is a reasonable probability that, but for counsel's failings, the result would have been more favorable to defendant. [Citation.] . . . 'When a claim of ineffective assistance is made on direct appeal, and the record does not show the reason for counsel's challenged actions or omissions, the conviction must be affirmed unless there could be no satisfactory explanation.' [Citations.]" (People v. Grimes (2015) 60 Cal.4th 729, 773.)

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