Can a prosecutor disparage a defense counsel?

Here, we agree with the trial court, which determined the prosecutor had not disparaged defense counsel. The prosecutor never accused the defense of fabrication or deceit. Instead, the prosecutor was merely commenting on the defenses' anticipated arguments. Likewise, although the prosecutor said the pastor had "been through enough already[,]" and the defense would call him a liar, it was clear the defense was going to attack the pastor's credibility. The prosecutor was describing the defenses' anticipated comments and the deficiencies in the defense position. Such comments do not amount to misconduct. (See People v. Bemore, supra, 22 Cal.4th at p. 846 [prosecutor may describe deficiencies in opposing counsel's tactics].) When the prosecutor's comments are considered in context, there is no likelihood the jury would have understood them as anything but criticism of the anticipated tactical approach offered by the defense, which is allowed. (People v. Linton (2013) 56 Cal.4th 1146, 1206.)