What constitutes misconduct in a prosecutor's response to a defense counsel's defence?

improperly imply that defense counsel was lying or was obligated or permitted to present a defense dishonestly. The remarks were partially in response to defense counsel's argument that the prosecution could not admit to doubt because the prosecution's job was to try to erase all doubt, an argument in which counsel characterized the prosecutor as a bulldozer, trampling reasonable doubt and stubborn facts, and flattening the case into a smooth plane of simplicity that left only an easy decision for the jury. We believe the jury viewed these dueling comments, at least to some extent, as equivalent rhetorical strikes. Furthermore, as our review of relevant case law demonstrates, courts have found remarks more egregious than the prosecutor's remarks in this case "not [to] exceed the bounds of permissible vigor." (Gionis, supra, 9 Cal.4th at p. 1218.) The challenged remarks were within the wide latitude allowed the prosecutor in describing the deficiencies in defense counsel's tactics and factual account. (People v. Redd, supra, 48 Cal.4th at p. 735.) Thus, they did not constitute misconduct.