What is the standard of review for a prosecution rebuttal summation in a criminal case?

Defendants advance a litany of objections to the prosecution's rebuttal summation. In reviewing these objections, we are mindful both of the trial court's criticism, see, e.g., United States v. Bonventre, 2014 WL 3673550, at *16 (characterizing many remarks in

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rebuttal summation as "ill-conceived and unworthy of the institutional stature of the United States Attorney's Office"), and its ultimate rejection of defendants' due process challenge in the context of (1) the "meticulous presentation" of incriminating evidence; (2) the totality of arguments made at trial; and (3) contemporaneous curative instructions, id. Having carefully reviewed the record, we identify no abuse of discretion in this conclusion. See United States v. Banki, 685 F.3d 99, 119-20 (2d Cir. 2012) (identifying standard of review).

1. Severity of Misconduct