The following excerpt is from Berryman v. Chappell, Case No.: 1:95-cv-05309 AWI (E.D. Cal. 2013):
prosecutor's conduct was so significant that it rendered the trial fundamentally unfair. Donnelly v. DeChristoforo, 416 U.S. 637, 647-48 (1974). To meet this standard, the conduct must have "so infected the trial process with unfairness as to make the resulting conviction a denial of due process." Id. at 643, quoted by Dardan v. Wainwright, 477 U.S. 168, 181 (1986).
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