Is it misconduct for a prosecutor to imply that defense counsel has fabricated evidence or otherwise to portray defense counsel as the villain in the case?

It is "improper for the prosecutor to imply that defense counsel has fabricated evidence or otherwise to portray defense counsel as the villain in the case." (People v. Sandoval (1992) 4 Cal.4th 155, 183.) But it is not misconduct to challenge "the persuasive force of defense counsel's closing argument." (People v. Zambrano (2007) 41 Cal.4th 1082, 1155, disapproved on other grounds in People v. Doolin (2009) 45 Cal.4th 390, 421, fn. 22.)

In the referenced rebuttal argument, the prosecutor did not imply defense counsel "fabricated a defense." Rather, she was arguing the evidence should be read differently from the manner defense counsel argued, and that Doe 3's statements could be reconciled. This did not amount to an attack on defense counsel personally, but rather was a permissible challenge to the persuasive force of defense counsel's closing argument. (See People v. Dykes, supra, 46 Cal.4th at p. 772.)