How have the courts treated comments made by counsel to the jury in defense counsel in cases involving misconduct allegations?

The other instances of alleged misconduct were comments on defense counsel's treatment of the evidence, not on defense counsel himself, and at worst were "clearly recognizable as an advocate's hyperbole." (People v. Sandoval (1992) 4 Cal.4th 155, 184.) Telling the jury that defense counsel was "probably going to ignore a lot of evidence that points to his client's guilt that I'm going to ask you to focus on" was essentially stating the obvious, that each attorney would focus on the evidence favorable to his side. The statement, "I think [defense counsel] ignores reality," was a reference to defense counsel arguing that certain things did not happen because a witness said he or

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