The following excerpt is from U.S. v. Bazua-Vizcarra, 927 F.2d 611 (9th Cir. 1991):
Prosecutors should "avoid directly accusing a defendant of lying--since jurors could believe the government has knowledge outside the evidence about the defendant's veracity." United States v. Garcia, 818 F.2d 136, 144 (1st Cir.1987). Such statements implicate the same fairness concerns outlined with respect to the prosecutor's comments vouching for evidence.
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