The following excerpt is from Campbell v. McCormick, 956 F.2d 1166 (9th Cir. 1992):
A prosecutor may not express his personal opinion of the defendant's guilt or the credibility of witnesses. United States v. McCoy, 771 F.2d 1207, 1210-11 (9th Cir.1985). However, to constitute grounds for habeas relief, the prosecutor's statements must have rendered the trial fundamentally unfair. Campbell v. Kincheloe, 829 F.2d at 1457. Mere improper argument does not necessarily violate a defendant's constitutional rights. Id.
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