What is the test for admonishing a prosecutor in a criminal case against a defendant not to create straw men?

In People v. Cunningham (2001) 25 Cal.4th 926, 1002, the court determined that similar remarks by the prosecutor were "not so extreme that an admonition would not have cured any harm. [Citation.]" In that case, the prosecutor had argued that the defense attorneys' job was "to create straw men. Their job is to put up smoke, red herrings. And they have done a heck of a good job. And my job is to straighten that out and show you where the truth lies." (Ibid.)

Here, after defendant's trial counsel objected, the jury was admonished to disregard the prosecutor's argument. "We presume that the jury heeded the admonition and any error was cured. [Citation.]" (People v. Wash (1993) 6 Cal.4th 215, 263.) Moreover, the challenged remarks were a relatively minor part of the prosecutor's argument, and "[t]hey were clearly recognizable as an advocate's hyperbole. [Citation.]" (Sandoval, supra, 4 Cal.4th at p. 184.) "Accordingly, we find no reasonable probability that the jury would have reached a more favorable result absent the objectionable comments. [Citation.]" (Ibid.; see People v. Watson (1956) 46 Cal.2d 818, 836.)