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¶13 Turning to the inquiry here, “[t]o prevail on a claim of prosecutorial misconduct, a defendant must demonstrate that the prosecutor’s misconduct so infected the trial with unfairness as to make the resulting conviction a denial of due process.” ¶ 46 (2007) ( ¶ 26 (1998)) (internal quotation marks omitted).

¶9 To prove reversible error based on prosecutorial misconduct, “a defendant must demonstrate that the prosecutor’s misconduct so infected the trial with unfairness as to make the resulting conviction a denial of due process.” ¶ 193 (2016) ( ¶ 26 (1998)).

4 STATE v. ROMERO Decision of the Court with unfairness as to make the resulting conviction a denial of due process.” Goudeau, 239 Ariz. at 465, ¶ 193 ( ¶ 26 (1998) (internal quotation marks and citation omitted)).

engaged in a pattern of error at trial, which deprived him of a fair trial and due process of law.1 ¶17 “To prevail on a claim of prosecutorial [error], a defendant must demonstrate that the prosecutor’s [error] so infected the trial with unfairness as to make the resulting conviction a denial of due process.” ¶ 46 (2007) ( ¶ 26 (1998)) (internal quotation marks omitted).

“To prevail on a claim of prosecutorial misconduct, a defendant must demonstrate that the prosecutor’s misconduct ‘so infected the trial with unfairness as to make the resulting conviction a denial of due process.’” ¶ 26 (1998) (quoting Donnelly v. DeChristoforo, 416 U.S. 637, 643 (1974)).

“To prevail on a claim of prosecutorial misconduct, a defendant must demonstrate that the prosecutor’s misconduct so infected the trial with unfairness as to make the resulting conviction a denial of due process.” ¶ 46 (2007) ( ¶ 26 (1998)) (internal quotation marks omitted).

¶ 75 (2008) (“Absent any finding of misconduct, there can be no cumulative effect of misconduct sufficient to permeate the entire atmosphere of the trial with unfairness.”); ¶ 26 (1998) (explaining that alleged prosecutorial error instances are evaluated for cumulative effect).

See State v. Hughes, 3 STATE v. DOMPKOWSKI Decision of the Court ¶ 58 (1998); ¶ 4 (App. 2008) (“[A]n objection on one ground does not preserve the issue on another ground.

“To determine whether a particular argument is improper, the statements must be examined in context to determine whether the jury would naturally and necessarily perceive them to be a comment on the failure of the defendant to testify.” ¶ 62 (1998) (considering the “cumulative effect” of prosecutor’s statements).

¶ 51 (2007) ( ¶ 59 (1998)).

and certainly did not rise to the level of fundamental error”), ¶ 61 (1998) (finding misconduct for a prosecutor’s remarks that defense counsel and experts “fabricated” an insanity defense without supporting evidence).

1 ¶ 26 (1998) (discussing the cumulative effect doctrine regarding prosecutorial misconduct in general and making no distinction between harmless and 1 Prior cases are also inconsistent in discussing whether a claim of error that is, in fact, not error can still be considered for a finding of cumulative error.

¶ 145 (2004) The defendant must not only show misconduct occurred, but also establish the misconduct “so infected the trial with unfairness as to make the resulting conviction a denial of due process.” ¶ 26 (1998).

“To prevail on a claim of prosecutorial misconduct, a defendant must demonstrate that the prosecutor’s misconduct so infected the trial with unfairness as to make the resulting conviction a denial of due process.” ¶ 193 (2016) ( ¶ 26 (1998)).

¶7 Proving prosecutorial misconduct is not an easy task; “[t]o prevail on a claim of prosecutorial misconduct, a defendant must demonstrate that the prosecutor’s misconduct so infected the trial with unfairness as to make the resulting conviction a denial of due process.” ¶ 193 (2016) ( ¶ 26 (1998)).

e ¶ 41 (2002) (“[A] prosecutor has an obligation not only to prosecute with diligence, but to 11 STATE v. ARIAS Opinion of the Court seek justice” and “must refrain from all use of improper methods designed solely to obtain a conviction”); ¶ 33 (1998) (“The prosecutor has an obligation to seek justice, not merely a conviction, and must refrain from using improper methods to obtain a conviction.”).

¶21 To establish prosecutorial misconduct, a defendant must show the misconduct “so infected the trial with unfairness as to make the resulting conviction a denial of due process,” and prove the misconduct was “so pronounced and persistent that it permeates the entire atmosphere of the trial.” ¶ 46 (2007) ( ¶ 26 (1998)).

If the comment rises to misconduct, the defendant must show the prosecutor’s misconduct “so infected the trial with unfairness as to make the resulting conviction a denial of due process.” ¶ 193 (2016) ( ¶ 26 (1998)).

“To prevail on a claim of prosecutorial misconduct, a defendant must demonstrate that the prosecutor’s misconduct so infected the trial with unfairness as to make the resulting conviction a denial of due process.” ¶ 46 (2007) ( ¶ 26 (1998)).

A defendant must demonstrate that the “prosecutor’s misconduct ‘so infected the trial with unfairness as to make the resulting conviction a denial of due process.’” ¶ 26 (1998) (citation omitted).

“[w]e’ve heard no evidence otherwise.” Though under different circumstances such statements could amount to commenting on a defendant’s silence, this single statement regarding evidence that could have been challenged in numerous ways does not rise to the level of a comment “calculated to direct the jurors’ attention to the defendant’s exercise of his Fifth Amendment privilege.” ¶ 64 (1998) ().

¶14 Anderson has the burden to show that the “prosecutor’s misconduct so infected the trial with unfairness as to make the resulting conviction a denial of due process.” ¶ 26 (1998) (quotation omitted).