What is the legal test for a defense counsel to have objected to a prosecutor's closing argument?

Appellant did not satisfy this burden. "An attorney may choose not to object for many reasons, and the failure to object rarely establishes ineffectiveness of counsel. [Citation.]" (People v. Kelly (1992) 1 Cal.4th 495, 540.) In this case, defense counsel primarily focused on self-defense during his closing argument. He might have decided that an objection and admonishment during the portion of the prosecutor's arguments devoted to voluntary manslaughter would only have highlighted them in the minds of the jurors. Alternatively, he reasonably could have concluded that objection might have been poorly received by the jury or that it would have called undue attention to an otherwise forgettable argument. In the heated atmosphere of trial, defense counsel is in the best position to determine appropriate tactical choices based on his assessment of the jury's reaction to the proceedings. (See, e.g., People v. Jackson (1980) 28 Cal.3d 264, 291-

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