Editor’s Note: The published opinion in this case involved other issues as well.

A jury convicted Taylor of kidnapping to commit robbery as well as of the robbery itself. The trial court sentenced Taylor to prison and imposed fines and fees prior to the Dueñas decision. On appeal, Taylor challenged the fines and fees based on Dueñas.

Holdings/Reasoning:

• Taylor forfeited his Dueñas claims because he did not object to the fines and fees in the trial court. (Citing People v. Frandsen (2019) 33 Cal.App.5th 1126.
• Taylor’s trial counsel did not render ineffective assistance by failing to object to the assessments and fees that were imposed without a determination of Taylor’s ability to pay. Failure to object rarely amounts to constitutionally ineffective representation. Taylor did not demonstrate his lawyer’s conduct fell below an objective standard of reasonableness.