What is the test for ineffective assistance of counsel?

To establish a claim of ineffective assistance of counsel, a defendant must first show that his or her counsel's performance was deficient, which is representation that was below an objective standard of reasonableness. (People v. Nguyen (2015) 61 Cal.4th 1015, 1051.) A strong presumption exists that counsel's conduct fell within the wide range of reasonable professional representation. (Ibid.) "'In the usual case, where counsel's trial tactics or strategic reasons for challenged decisions do not appear on the record, we will not find ineffective assistance of counsel on appeal unless there could be no conceivable reason for counsel's acts or omissions.' [Citation.] For this reason, claims of ineffective assistance of counsel 'are ordinarily best raised and reviewed on habeas corpus.' [Citation.]" (Ibid.)

The parties dispute whether or not defense counsel had a tactical reason for not objecting. Appellant contends there was no reasonable tactical basis for his counsel to withhold an objection or seek an admonition. Appellant relies on lower federal court authority and argues it is not an objectively reasonable tactical choice to have a general fear "an objection would do more harm than good because it would focus the jurors' attention on the prosecutor's statement even if the court instructed them otherwise." (Washington v. Hofbauer (6th Cir. 2000) 228 F.3d 689, 705-706, fn. omitted.)