Can a prosecutor commit misconduct under the federal penalty standard at the penalty phase of a criminal case?

As at the guilt phase of the trial, at the penalty phase a prosecutor commits misconduct under the federal standard by engaging in conduct that renders the trial so unfair as to constitute a denial of due process. [Citations.] State law characterizes the use of deceptive or reprehensible methods as misconduct. (People v. Dykes (2009) 46 Cal.4th 731, 786, 95 Cal.Rptr.3d 78, 209 P.3d 1.)