How have the courts treated a prosecutor's appeal to the jurors' sympathy for the victim during closing argument?

Finally, as discussed ante, the evidence of appellant's guilt of first degree murder was overwhelming. There is "no reasonable probability that the prosecutor's appeal to the jurors' sympathy for the victim affected the verdict rendered. [Citation.]" (People v. Fields, supra, 35 Cal.3d at p. 363; see Drayden v. White, supra, 232 F.3d at pp. 713-714 [no due process violation resulted from prosecutor's soliloquy of victim during closing argument where, had the prosecutor delivered exactly the same speech in the third person, it would have been proper; court instructed jury that attorney's statements were not evidence and jury must not be influenced by sympathy; and evidence of first degree murder was very strong].)