What is the test for a defense objection to a prosecutor's argument in a civil case?

The prosecutor's arguments were not improper, therefore there was no reason for defense objection. The failure to object did not violate defendant's right to effective assistance of counsel. (See People v. Lopez (2008) 42 Cal.4th 960, 970.)

To establish ineffective assistance of counsel, a "defendant must demonstrate that: (1) his attorney's performance fell below an objective standard of reasonableness; and (2) there is a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been more favorable to the defendant." (People v. Stanley, supra, 39 Cal.4th at p. 954, citing Strickland v. Washington (1984) 466 U.S. 668, 688, 694.) A reasonable probability is a probability sufficient to undermine confidence in the outcome. (Ibid.)

Even if the prosecutor's statement was improper, defendant would still not be entitled to relief. "[E]xcept in those rare instances where there is no conceivable tactical purpose for counsel's actions, claims of ineffective assistance of counsel should be raised on habeas corpus, not on direct appeal." (People v. Lopez, supra, 42 Cal.4th at p. 972.) This is especially true when the alleged incompetence arises from counsel's failure to object. (Ibid.)