What is the test for an ineffective assistance of counsel claim?

Recognizing the forfeiture problem, defendant argues his counsel was ineffective for failing to object. " 'A defendant whose counsel did not object at trial to alleged prosecutorial [error] can argue on appeal that counsel's inaction violated the defendant's constitutional right to the effective assistance of counsel.' " (People v. Centeno (2014) 60 Cal.4th 659, 674.) To establish ineffective assistance of counsel, defendant must

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show, by a preponderance of the evidence, that " '(1) counsel's representation fell below an objective standard of reasonableness under prevailing professional norms, and (2) counsel's deficient performance was prejudicial, i.e., there is a reasonable probability that, but for counsel's failings, the result would have been more favorable to the defendant.' " (People v. Johnson (2015) 60 Cal.4th 966, 980.)

In evaluating an ineffective assistance of counsel claim on appeal, we presume, absent defendant's contrary showing, that " ' "counsel's performance fell within the wide range of professional competence and that counsel's actions and inactions can be explained as a matter of sound trial strategy." ' [Citations.] When the record on direct appeal sheds no light on why counsel failed to act in the manner challenged, defendant must show that there was ' " 'no conceivable tactical purpose' " for counsel's act or omission. [Citations.]' '[T]he decision facing counsel in the midst of trial over whether to object to comments made by the prosecutor in closing argument is a highly tactical one' . . . [citations], and 'a mere failure to object to evidence or argument seldom establishes counsel's incompetence' [citation]." (People v. Centeno, supra, 60 Cal.4th at pp. 674-675.)