The following excerpt is from Demirdjian v. Gipson, 832 F.3d 1060 (9th Cir. 2016):
Absent egregious misstatements by the prosecution, defense counsel's failure to object during closing argument is typically considered a reasonable strategic decision that falls within the wide range of permissible professional legal conduct. Cunningham v. Wong , 704 F.3d 1143, 1159 (9th Cir. 2013). Here, the prosecution's clear and repeated statements that the defense was required to provide competent, admissible evidence were egregious misstatements. These misstatements went
[832 F.3d 1082]
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