Does a Defendant's failure to submit instructions on the issue of venue constitute a waiver or forfeiture?

12. Defendant contends that defense counsel's failure to submit instructions on the issue of venue should not be construed as a waiver or forfeiture, because it was based on ignorance of the law rather than a deliberate choice. Defendant cites no authority to support this argument. Furthermore, because the right to a jury trial on venue, as it existed at the time of defendant's trial, was based on state case law and not a state or federal constitutional right, it could be forfeited without a personal, express waiver. (See People v. Vera (1997) 15 Cal.4th 269, 278, 62 Cal.Rptr.2d 754, 934 P.2d 1279 [right to jury trial on prior conviction allegations, which is purely statutory right, may be forfeited by failure to object].)

13. "Jurisdictional territory," in this context, signifies a county. ( 691, subd. (b).)

14. Because venue generally was treated as an issue for the jury prior to our decision in People v. Posey, supra, 32 Cal.4th 193, 8 Cal. Rptr.3d 551, 82 P.3d 755, the case law does not establish whether the trial court's ruling on venue should be reviewed under a deferential or independent standard. As we concluded regarding the court's ruling on territorial jurisdiction (ante, 23 Cal.Rptr.3d p. 150, 103 P.3d p. 893), we would uphold the trial court's ruling that venue was proper in Riverside County under either standard.