What is the current state of the law on the interpretation of the Fifth Amendment when a prosecutor makes an indirect comment about a defendant's failure to testify?

The Fifth Amendment to the United States Constitution forbids either comment by the prosecution on the accused's silence or instructions by the court that such silence is evidence of guilt. Griffin v. California , 380 U.S. 609, 615, 85 S.Ct. 1229, 14 L.Ed.2d 106 (1965). While a direct comment about the defendant's failure to testify always violates Griffin , a prosecutor's indirect comment violates Griffin only if it is manifestly intended to call attention to the defendant's failure to testify, or is of such a character that the jury would naturally and necessarily take it to be a comment on the failure to testify. Hovey v. Ayers , 458 F.3d 892, 912 (9th Cir.2006), quoting Lincoln v. Sunn , 807 F.2d 805, 809 (9th Cir.1987).