What is the test for a motion to suppress evidence seized after a warrantless search?

As respondent points out, however, defendant abandoned this claim at the trial level, never asking the court, which had declined to rule before submission of points and authorities, for a ruling on the motion and never filing the points and authorities requested by the trial court. (See People v. Pinholster (1992) 1 Cal.4th 865, 931, 4 Cal.Rptr.2d 765, 824 P.2d 571; People v. Kaurish (1990) 52 Cal.3d 648, 680, 276 Cal.Rptr. 788, 802 P.2d 278.)

Defendant alleges that trial counsel provided ineffective assistance in various respects, in violation of his state and federal constitutional right to the effective assistance of counsel. "To prevail on such claims, he must establish not only deficient performance, i.e., representation below an objective standard of reasonableness, but also resultant prejudice. [Citation.] Tactical errors are generally not deemed reversible, and counsel's decisionmaking must be evaluated in the context of the available facts. [Citation.] To the extent the record on appeal fails to disclose why counsel acted or failed to act in the manner challenged, we will affirm the judgment `unless counsel was asked for an explanation and failed to provide one, or unless there simply could be no satisfactory explanation....' [Citation]. Finally, prejudice must be affirmatively proved; the record must demonstrate `a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been different. A reasonable probability is a probability sufficient to undermine confidence in the outcome.' [Citations.]" (People v. Bolin, supra, 18 Cal.4th at p. 333, 75 Cal.Rptr.2d 412, 956 P.2d 374.)

a. Failure to move to suppress evidence seized after a warrantless search