What is the test for a defense counsel to object to the use of restraints on a defendant in transit outside the courthouse?

functioning as the 'counsel' guaranteed the defendant by the Sixth Amendment. Second, the defendant must show that the deficient performance prejudiced the defense. This requires showing that counsel's errors were so serious as to deprive the defendant of a fair trial, a trial whose result is reliable." (Strickland v. Washington (1984) 466 U.S. 668, 687.)

Walters has not satisfied either prong.

The first prong is met only "if the record on appeal demonstrates there could be no rational tactical purpose for counsel's omissions." (People v. Lucas (1995) 12 Cal.4th 415, 442.) In this case, counsel could have reasonably concluded that any objection to the security measures would likely have been overruled. As noted, law enforcement officials have broad discretion to provide security while a defendant is in transit in a public area of the courthouse, and a court's approval of these measures is unnecessary. (People v. Cunningham, supra, 61 Cal.4th at p. 632.) This rule applies with particular force in the existing San Diego County courthouse where it is generally not feasible in practical terms to avoid the public hallways when escorting defendants to and from the courtrooms. Because the use of restraints during transport is within law enforcement's sound discretion, defense counsel could have reasonably decided that an objection would have been without merit. Counsel's decision to forego a meritless objection is not deficient performance. (People v. Lucero (2000) 23 Cal.4th 692, 732.)