When a defendant fails to raise an issue in the opening brief, raising it for the first time in the reply brief, is a claim of ineffective assistance forfeited?

However, when a defendant fails to raise an issue in the opening brief, raising it for the first time in a reply brief, we generally decline to address the issue or address it in a summary manner. (See People v. Duff (2014) 58 Cal.4th 527, 550, fn. 9 [claim of ineffective assistance of counsel raised by defendant for the first time in reply brief is forfeited]; People v. Harris (2008) 43 Cal.4th 1269, 1290 [defendant's claim of ineffective assistance of counsel for failure to object to prosecutor's argument, made for first time in reply brief in response to waiver argument, "is as meritless as it is belated"];

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People v. Alvarez (1996) 14 Cal.4th 155, 241, fn. 38 ["'perfunctorily'" rejecting defendant's claim of ineffective assistance of counsel, made for the first time in reply brief and in a single paragraph].)