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¶ 22, 551 ¶ 27 (2021) (finding fundamental prejudicial error where, despite a proper jury instruction, the prosecutor misstated the reasonable doubt standard).

See State v. (Easton C.) Murray, ¶ 14 (2021).

After further learning Vazquez had stopped working for SP Richards several weeks earlier, the manager called the 1 Because there is no allegation that the prosecutor committed intentional misconduct in this case, we refer to the prosecutor’s conduct as “prosecutorial error.” ¶ 12 (2021) (characterizing a prosecutor’s incorrect reasonable-doubt statement as “error” rather than “misconduct” in the absence of evidence that the prosecutor’s actions were intentional).

To successfully show prosecutorial error, Wilson must show “the prosecutor’s [error] so infected the trial with unfairness as to make the resulting conviction a denial of due process.” ¶ 13 (2021) (citation and internal quotation marks omitted).

¶44 Although the State argues, and the Majority concludes, reversal is not warranted because the reference was quick, made briefly during rebuttal argument following two weeks of trial testimony, our supreme court recently recognized that even brief misstatements can carry great prejudice when they are “made in rebuttal argument when the words [are] most impactful.” ¶ 37 (2021).

¶75 To prevail on a claim of prosecutorial error, a defendant must show “that the prosecutor’s [error] so infected the trial with unfairness as to make the resulting conviction a denial of due process.” ¶ 13 (2021) ( ¶ 46 (2007)).

We review a single, unobjected-to prosecutorial statement for fundamental error.2 ¶ 16 (2021) (citing Escalante, 245 Ariz. at 144, ¶ 31).

When the defendant properly objects at trial, as here, we will reverse only if the defendant can show “(1) misconduct exists and (2) ‘a reasonable likelihood exists that the misconduct could have affected the jury’s verdict, thereby denying defendant a fair trial.’” ¶ 13 (2021) (citation omitted).

-54, ¶¶ 37, 40 (2021) (defendant’s due process rights were violated, and his conviction overturned, where prosecutor misstated the reasonable-doubt standard).

¶ 14 (2021) (citing Escalante, 245 Ariz. at 138, ¶ 1).

so profoundly distort[s] the trial that injustice is obvious without the need to further consider prejudice.”); ¶ 1 (2021) (applying Escalante and holding that “prosecutor’s material misstatement of the reasonable-doubt standard was both fundamental and prejudicial error because it went to the foundation of the case and deprived Defendants of an essential right”).