California, United States of America
The following excerpt is from People v. Garcia, C081200 (Cal. App. 2018):
Defendant urges us to address the contention anyway in the interest of judicial economy to prevent a claim of ineffective assistance of counsel. However, we need not consider the matter because defendant does not develop an analysis of ineffective assistance of counsel on this point. (People v. Duff (2014) 58 Cal.4th 527, 550, fn. 9
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[defendant forfeited claim of ineffective assistance of counsel by raising it for the first time in the reply brief].)
Defendant fails to show grounds for reversal based on cruel and/or unusual punishment.
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