What constitutes prosecutorial misconduct in a criminal case?

Prosecutorial misconduct under federal law exists when there is a pattern of conduct so egregious as to render a defendant's trial fundamentally unfair in violation of his or her federal constitutional due process rights. (People v. Cox (2003) 30 Cal.4th 916, 952, disapproved on another point in People v. Doolin (2009) 45 Cal.4th 390, 421, fn. 22.) "'"Conduct by a prosecutor that does not render a criminal trial fundamentally

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unfair is prosecutorial misconduct under state law only if it involves the use of deceptive or reprehensible methods to attempt to persuade either the trial court or the jury."' [Citation.]" (People v. Seumanu (2015) 61 Cal.4th 1293, 1331-1332.) Deceptive or reprehensible methods include personal attacks on opposing counsel's integrity. (People v. Gionis (1995) 9 Cal.4th 1196, 1215.) A prosecutor also may not falsely accuse defense counsel of fabricating a defense. (People v. Stitely (2005) 35 Cal.4th 514, 560.) However, '""[w]hat is crucial to a claim of prosecutorial misconduct is not the good faith vel non of the prosecutor, but the potential injury to the defendant." [Citation.]' [Citation.]" (People v. Cox, supra, 30 Cal.4th at p. 952.) "'A defendant's conviction will not be reversed for prosecutorial misconduct' that violates state law . . . 'unless it is reasonably probable that a result more favorable to the defendant would have been reached without the misconduct.' [Citation.]" (People v. Wallace (2008) 44 Cal.4th 1032, 1071.)