What is the test for alleging misconduct by a prosecutor in a criminal case?

"Although defendant singles out words and phrases, or at most a few sentences, to demonstrate misconduct, we must view the [prosecutor's] statements in the context of the argument as a whole. [Citation.]" (People v. Dennis (1998) 17 Cal.4th 468, 522.) In assessing defendant's claim that the prosecutor made improper arguments to the jury, we "must determine at the threshold how the remarks would, or could, have been understood by a reasonable juror. [Citations.]" (People v. Benson (1990) 52 Cal.3d 754, 793.)

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A. Prosecution Argument re Burden of Proof and Circumstantial Evidence