What is the test for ineffective assistance of counsel?

Generally, "in the heat of a trial, defense counsel is best able to determine proper tactics in the light of the jury's apparent reaction to the proceedings. The choice of when to object is inherently a matter of trial tactics not ordinarily reviewable on appeal." (People v. Frierson (1991) 53 Cal.3d 730, 749.) In other words, because "[t]he appellate record . . . rarely shows that the failure to object was the result of counsel's incompetence . . . , such claims are more appropriately litigated on habeas corpus, which allows for an evidentiary hearing where the reasons for defense counsel's actions or omissions can be explored." (Lopez, supra, 42 Cal.4th at p. 966.) Thus, reversal on direct appeal for ineffective assistance of counsel is warranted only if "(1) the record affirmatively discloses counsel had no rational tactical purpose for the challenged act or omission, (2) counsel was asked for a reason and failed to provide one, or (3) there simply could be no satisfactory explanation." (Mai, supra, 57 Cal.4th at p. 1009.)

3. Contrasting the defendants on trial to Reed and Ward