California, United States of America
The following excerpt is from People v. Franco, 24 Cal.App.4th 1528, 30 Cal.Rptr.2d 478 (Cal. App. 1994):
For a prosecutor, during argument, to characterize such a gang member as "hard core," "experienced," and "sophisticated" did not exceed the bounds of vigorous and fair argument. (People v. Edelbacher (1989) 47 Cal.3d 983, 1030, 254 Cal.Rptr. 586, 766 P.2d 1 [the prosecutor referred to the defendant as a "contract killer," "a snake in the jungle," "slick," "tricky," a "pathological liar," and "one of the greatest liars in the history of Fresno County"].)
2. Appellant contends the trial court erred in giving an unmodified accomplice instruction (CALJIC No. 3.18).
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