What is the test for misconduct in a criminal case where the prosecutor used "deceptive or reprehensible methods" to persuade either the court or the jury?

Prosecutorial misconduct will be found where the prosecutor uses "'"deceptive or reprehensible methods to attempt to persuade either the court or the jury."' [Citation.]" (People v. Espinoza (1992) 3 Cal.4th 806, 820.) Deceptive or reprehensible methods include the insinuation that defense counsel "was acting in bad faith in challenging the sufficiency" of the evidence. (People v. Perry (1972) 7 Cal.3d 756, 790 (Perry).) In Perry, the prosecutor asserted that defense counsel was acting in bad faith in challenging the sufficiency of the police report and by implying that defense counsel had improperly

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