California, United States of America
The following excerpt is from People v. Rubio, A152661 (Cal. App. 2018):
48 Cal.4th 691, 742.) But it remains the defendant's burden to show a reasonable likelihood that the jury understood or applied the prosecutor's comments in an improper or erroneous manner. (People v. Dykes (2009) 46 Cal.4th 731, 771-772.)
3. Analysis
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