California, United States of America
The following excerpt is from People v. Bonilla, F070035 (Cal. App. 2016):
12. Given our rejection of defendant's claim on the merits, we do not reach his claim of ineffective assistance of counsel claim, but observe "that a defendant cannot automatically transform a forfeited claim into a cognizable one merely by asserting ineffective assistance of counsel." (People v. Thompson (2010) 49 Cal.4th 79, 121, fn. 14.)
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