What is the test to overcome forfeiture in a civil case?

^5. To overcome forfeiture, appellant raises a claim of ineffective assistance of counsel. We reject this assertion. Because appellant's Dueas-related claim and his constitutional challenges have no merit, he cannot establish ineffective assistance of counsel. A defense attorney is not required to make futile motions or to engage in " 'idle acts to appear competent.' [Citation.]" (People v. Scheer (1998) 68 Cal.App.4th 1009, 1024.) An attorney is not deemed incompetent when he or she fails to lodge meritless objections. (People v. Lucero (2000) 23 Cal.4th 692, 732.)