What is the test for ineffective assistance of counsel?

To establish ineffective assistance of counsel, a defendant must show counsel's performance was "deficient, in that it fell below an objective standard of reasonableness under prevailing professional norms." (People v. Mai (2013) 57 Cal.4th 986, 1009.) Defendant must also show "resulting prejudice, i.e., a reasonable probability that, but for counsel's deficient performance, the outcome of the proceeding would have been different." (Ibid.)

A reviewing court defers to "counsel's reasonable tactical decisions . . . , and there is a 'strong presumption that counsel's conduct falls within the wide range of reasonable professional assistance.' " (People v. Lucas (1995) 12 Cal.4th 415, 436-437.) Defendant has a heavy burden on appeal, as a reviewing court will reverse a conviction based on incompetence of counsel " ' "only if the record on appeal affirmatively discloses that counsel had no rational tactical purpose for [his or her] act or omission." ' " (Id. at p. 437.)

The record is silent as to why defendant's trial counsel did not present expert evidence regarding prison culture or defendant's mental capacity. In these circumstances, a reviewing court will reject a claim of ineffective assistance of counsel unless counsel was asked for an explanation and failed to provide one or there simply could be no satisfactory explanation.² (People v. Mendoza Tello (1997) 15 Cal.4th 264, 266; see also People v. Bolin (1998) 18 Cal.4th 297, 334 ["Whether to call certain witnesses is . . . a matter of trial tactics, unless the decision results from the unreasonable failure to investigate."].) The record does not indicate counsel was asked for an explanation. In addition, counsel may have determined such evidence was unnecessary,

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