What is the impact of a prosecutor's closing argument on the reasonable doubt standard?

In each of the cases relied upon by Appellants, the examples of everyday decisions made by jurors were expressly and unambiguously used to expound upon the reasonable doubt standard. By contrast, the prosecutor in the instant matter did not reference any every day decision a juror would make. The comments appear to be directed not at the burden of proof, but strength of the evidence. In fact, it appears the prosecution was arguing that the evidence of guilt was so convincing that the jurors would remain convinced over time. This definition of an abiding conviction is consistent with how our high court defined that phrase. (See People v. Brigham (1979) 25 Cal.3d 283, 290 [noting abiding connotes "[t]he lasting, permanent nature of the conviction . . . ."].) Put differently, there is nothing in the closing argument here that could lead the jury to believe the reasonable doubt standard is anything less burdensome than what is contained in CALCRIM No. 220, which was shown to the jury during the prosecution's closing argument. We determine the court did not err in finding no prosecutorial misconduct based on the closing argument.

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