What is the test for forfeiting a claim of procedural error at a hearing where the attorney representing appellant did not argue the trial court was required to take additional evidence relating to the imposition of special disabilities?

Here, the attorney representing appellant at the May 25, 2018 hearing did not argue the trial court was required to (1) take additional evidence relating to the imposition of the special disabilities, and (2) render an oral ruling as to each disability. These claims of procedural error easily could have been addressed if they had been raised at the hearing. Consequently, we conclude appellant has forfeited those claims of error. (See Cowan v. Superior Court (1996) 14 Cal.4th 367, 371 [forfeiture is the failure to make the timely assertion of a right and is distinct from waiver, which is the intentional relinquishment of a known right].)

Questions as to the sufficiency of the evidence are not subject to forfeiture and, consequently, objections need not be raised in the trial court to preserve the issue for appeal. (People v. Butler (2003) 31 Cal.4th 1119, 1128.) Accordingly, we address appellant's contentions that the imposition of each disability is not supported by substantial evidence. (See Walker, supra, 206 Cal.App.3d at pp. 1577-1578 [substantial evidence standard applies to findings of fact; appellant did not waive issue by failing to present evidence related to the special disabilities].)

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