California, United States of America
The following excerpt is from People v. Medina, B244849 (Cal. App. 2014):
Here, there is nothing in the four corners of the record to indicate defense counsel's motivation for his tactical decisions, which is reason enough to reject the issue on direct appeal. It would have been reasonable for defense counsel to opt not to object because the likelihood that the jury noticed the gun possession reference was small and objecting may have drawn more attention to the prior conviction. (See People v. Ghent (1987) 43 Cal.3d 739, 772-773 ["Counsel may well have tactically assumed that an objection or request for admonition would simply draw closer attention to the [inadmissible evidence]."].) But even if we were to conclude that no satisfactory explanations exist for counsel's decisions, any error was harmless.
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