California, United States of America
The following excerpt is from People v. Keese, F073539 (Cal. App. 2017):
Under these circumstances, we are confident beyond a reasonable doubt that, had the prosecutor not elicited testimony of prior arguments not specifically addressed in the in limine ruling, the jury would have reached the same verdicts. (See People v. Bolton (1979) 23 Cal.3d 208, 214 ["Whatever test of prejudice this court applies to the present case, it is certain that any reasonable jury would have reached the same verdict even in the absence of the prosecutor's remarks." (Fn. omitted.)].)
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