What is the test for ineffective assistance of counsel?

Defense counsel forfeited this theory of admissibility by failing to raise it below. (Evid. Code, 354, subd. (a); People v. Pearson (2013) 56 Cal.4th 393, 470, fn. 10.) Defendant contends, however, that this constituted ineffective assistance.

"In order to establish a claim for ineffective assistance of counsel, a defendant must show that his or her counsel's performance was deficient and that the defendant suffered prejudice as a result of such deficient performance. [Citation.] To demonstrate deficient performance, defendant bears the burden of showing that counsel's performance '"'"fell below an objective standard of reasonableness . . . under prevailing professional norms.'"'" [Citation.] To demonstrate prejudice, defendant bears the burden of showing a reasonable probability that, but for counsel's deficient performance, the outcome of the proceeding would have been different. [Citations.]" (People v. Mickel (2016) 2 Cal.5th 181, 198.)

"[W]e begin with the presumption that counsel's actions fall within the broad range of reasonableness, and afford 'great deference to counsel's tactical decisions.' [Citation.] . . . [D]efendant's burden [i]s 'difficult to carry on direct appeal,' as a reviewing court will reverse a conviction based on ineffective assistance of counsel on direct appeal only if there is affirmative evidence that counsel had '"'no rational tactical purpose'"' for an action or omission. [Citation.]" (People v. Mickel, supra, 2 Cal.5th at p. 198.)