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When a defendant fails to object to alleged prosecutorial misconduct at trial—as Westrom did—–300 (Minn. 2006), under which “the defendant has the burden to demonstrate that the misconduct constitutes (1) error, (2) that was plain.”

“[I]n cases involving unusually serious prosecutorial misconduct,” appellate courts have “required certainty beyond a reasonable doubt that the misconduct was harmless before affirming.” –99, 299 n.4 (Minn. 2006) (observing that “some [Minnesota Supreme Court] cases [had] used the Caron standard to analyze unobjected-to prosecutorial misconduct,” “conclud[ing] that appellate courts should use the plain error doctrine when examining unobjected-to prosecutorial misconduct,” and “leav[ing] for an

“An error is plain if it is ‘clear’ or ‘obvious,’ which is typically established ‘if the error contravenes case law, a rule, or a standard of conduct.’” ().

“An error is plain if it ‘contravenes case law, a rule, or a standard of conduct.’” ().

The modified plain-error analysis announced in State v. Ramey, 11 –300 (Minn. 2006), however, provides a limited exception to the harsh consequences of the common law forfeiture rule.

An error 25 is plain if it “contravenes case law, a rule, or a standard of conduct.”

d 294, 302 (Minn. 2006).

An error is plain if it is “clear” or “obvious,” meaning that it “contravenes case law, a rule, or a standard of conduct.” (quotations omitted).

-99 (Minn. 2006); n.2 (Minn. 2023) (indicating that the two-tiered harmless-error test is applicable in cases involving objected-to prosecutorial misconduct).

An error is plain if it is “clear” or “obvious,” meaning that it “contravenes case law, a rule, or a standard of conduct.” State v. Ramey , (quotation omitted).

“Because no objection was made, we apply the modified plain-error test outlined in Ramey,” under which “the defendant has the burden to demonstrate that the misconduct constitutes (1) error, (2) that was plain.” ().

“Under this approach, the defendant must establish the existence of an error that was plain, and then the burden shifts to the State to establish that the plain error did not affect the defendant’s substantial rights.” ().

We review claims of unobjected -to prosecutorial misconduct under a modified plain-error standard, considering whether there is “(1) error, (2) that is plain, and (3) affects substantial rights.” State v. Ramey

(“An error is plain if it is clear or obvious.

(noting that under this standard we consider whether there is (1) error, (2) that is plain, and (3) that affects the defendant’s substantial rights).