How have courts treated the issue of prosecutorial misconduct in a motion for a new trial?

^10. [Footnote 10 in original] Defendant's prosecutorial misconduct argument in his motion for new trial was based on alleged references by the prosecutor to defendant's failure to present a defense, so-called Griffin error (Griffin v. California (1965) 380 U.S. 609, 615). Arguably, this was insufficient to preserve the claim defendant seeks to raise on appeal for the additional reason that it was not even based on the same ground (misconduct by vouching for witnesses). (See e.g., People v. Hill (1998) 17 Cal.4th 800, 820 [a specific objection on the same ground is required to preserve an issue of prosecutorial misconduct for appeal].)