Does the Fifth Amendment prohibit a prosecutor from commenting to a jury on a defendant's silence?

We do not see unavoidable Griffin error as pressed by respondent. Griffin holds that the Fifth Amendment forbids a prosecutor from commenting to a jury on a defendant's silence. (Griffin, supra, 380 U.S. 609, 615.) Griffin does not apply to any silence but to constitutionally invoked silence. (People v. Lewis (2001) 25 Cal.4th 610, 670.) As we have explained, the pretext phone call did not implicate the Fifth Amendment, so defendant's refusal to continue the conversation with J.M. did not invoke a Fifth Amendment right to silence.