What is the standard of proof for a prosecutor to argue that a reasonable doubt standard is reasonable?

First, "it is error for the prosecutor to suggest that a 'reasonable' account of the evidence satisfies the prosecutor's burden of proof." (People v. Centeno, supra, 60 Cal.4th at p. 672.) "The standard of proof is a measure of the jury's level of confidence. It is not sufficient that the jury simply believe[s] that a conclusion is reasonable. It must be convinced that all necessary facts have been proven beyond a reasonable doubt. [Citation.]" (Id. at p. 672.)

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Second, "[i]t is likewise error to state that 'a defendant has a duty or burden to produce evidence, or a duty or burden to prove his or her innocence.' [Citations.] . . . If the defense chooses to produce evidence, the jury must, of course, consider it as part of the complete record before it. To that end, the prosecution can surely point out that interpretations proffered by the defense are neither reasonable nor credible. Nevertheless, even if the jury rejects the defense evidence as unreasonable or unbelievable, that conclusion does not relieve or mitigate the prosecutorial burden. The prosecution cannot suggest that deficiencies in the defense case can make up for shortcomings in its own." (People v. Centeno, supra, 60 Cal.4th at p. 673.)

In Ellison, the prosecutor argued, "[Y]ou have to look at whether or not it's reasonable or unreasonable for the defendant to be innocent." (People v. Ellison, supra, 196 Cal.App.4th at p. 1351.) Referring to the reasonable doubt standard, she said: "'It's not this unattainable standard. You've got to look at what's reasonable and what's unreasonable, when you look at all the evidence.'" (Id. at p. 1352.) "'Reasonable doubt is with the evidence that you're given. . . . Is it reasonable that the defendant's innocent[?]'" (Ibid.) We held that this was prosecutorial misconduct: "[T]he prosecutor improperly attempted to lessen the People's burden of proof by arguing to the jury that the beyond-reasonable-doubt standard required the jury to determine whether defendant's innocence was reasonable." (Id. at p. 1353.)