Does a prosecutor commit misconduct if she attacks the integrity of defense counsel?

A prosecutor commits misconduct if she attacks the integrity of defense counsel, or casts aspersions on defense counsel. (People v. Seumanu (2015) 61 Cal.4th 1293, 1337 (Seumanu).) "[A]lthough a prosecutor is accorded wide latitude in attacking the defense's case [citation], for a prosecutor to claim that defense counsel does not believe in his or her client's innocence is improper [citations]." (Id. at p. 1337.) "A prosecutor may vigorously challenge the validity of any defense, and can characterize the testimony of a witness, including the defendant, as untruthful, but to state or imply that defense counsel has fabricated a defense is generally misconduct. [Citations.]" (Ibid.) Arguing that a defense was a sham unsupported by the facts is permissible; arguing that defense counsel put forward a sham is not, as it improperly implies that defense counsel was personally dishonest. (Id. at pp. 1337-1338.)