California, United States of America
The following excerpt is from People v. Covarrubias, F077157 (Cal. App. 2020):
To prevail on a claim of prosecutorial misconduct based on remarks to the jury, a defendant must show a reasonable likelihood the jury understood or applied the disputed comments in an improper or erroneous manner. (People v. Centeno (2014) 60 Cal.4th 659, 667.) We must examine the prosecutor's entire argument and the jury instructions. (Ibid.)
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