What is the test for reversing a criminal conviction for prosecutorial misconduct?

"[R]eversing a criminal conviction for prosecutorial misconduct is a drastic remedy that courts generally are reluctant to implement." United States v. Valentine, 820 F.2d 565, 570 (2d

Page 6

Cir. 1987). We will reverse based on prosecutorial misconduct only if it "causes the defendant 'substantial prejudice' by 'so infecting the trial with unfairness as to make the resulting conviction a denial of due process.'" United States v. Shareef, 190 F.3d 71, 78 (2d Cir. 1999) (citation and alterations omitted). "In assessing whether a defendant has sustained substantial prejudice, we consider the severity of the alleged misconduct, any curative measures taken by the trial court, and the likelihood of conviction absent the challenged conduct." Newton, 369 F.3d at 680. Where a defendant failed to object to the challenged statement below, we review only for plain error. See United States v. Williams, 690 F.3d 70, 77 (2d Cir. 2012).