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

Palacios argues that his prison sentence of 50 years to life constitutes cruel and unusual punishment under the federal Constitution and cruel or unusual punishment under the state Constitution. He forfeited this argument by failing to raise it in the trial court. We nevertheless consider it to forestall an ineffective assistance of counsel claim. (See People v. Em (2009) 171 Cal.App.4th 964, 971-972, fn. 5.) As we explain, Palacios fails to show his sentence was unconstitutional under either the federal or state Constitutions.