When will a defendant be able to argue that his attorney objected to the reference in argument?

California, United States of America

The following excerpt is from People v. Campos, A133830 (Cal. App. 2013):

Defendant cannot establish the reasonable probability he would have realized a more favorable outcome had his attorney objected to the reference in argument. (Strickland v. Washington, supra, 466 U.S. at pp. 693-694.) The trial court did provide a limiting instruction concerning statements of counsel. This minimized any prejudice. More importantly, the evidence of defendant's guilt was substantial. Defendant's brief falls considerably short of the proper mark to demonstrate prejudice and we reject it.

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