How have courts dealt with allegations of misconduct in closing argument?

^33. In his opening brief, defendant states that in closing argument, the prosecutor engaged in "numerous" instances of denigrating the defense. With respect to any such assertions, " 'It is the duty of counsel to refer us to the portion of the record supporting [defendant's] contentions on appeal. [Citations.] . . . "It is neither practical nor appropriate for us to comb the record on [defendant's] behalf." ' [Citation.] We consider the record to which counsel does refer." (People v. Smith (2015) 61 Cal.4th 18, 48.)

^34. Although defense counsel objected that the prosecutor's remarks misstated the evidence rather than that they referred to facts not in evidence, we find the claim of misconduct sufficiently preserved. It is doubtful the trial court would have responded to the objection differently had it been more precisely made.

^35. Pitchess v. Superior Court (1974) 11 Cal.3d 531.