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“An error is plain if it was clear or obvious,” such as if “the error contravenes case law, a rule, or a standard of conduct.” (quotation omitted).

Claims of unobjected- to prosecutorial misconduct are reviewed pursuant to a modified-plain-error standard which first requires the defendant to demonstrate “that the prosecutor’s conduct constitutes an error that is plain,” then the burden shifts to the state “to demonstrate lack of prejudice.”

d 294, 302 (Minn. 2006).

Under this test, the defendant must first demonstrate “that the prosecutor’s conduct constitutes an error that is plain .” State v. Ramey , d 294, 302 (Minn. 2006) .

Claims of unobjected-to prosecutorial misconduct are revi ewed pursuant to a modified-plain-error standard which first requi res the defendant to demonstrate “that the prosecutor’s conduct constitutes an error that is plain,” then the burde n shifts to the state “to demonstrate lack of prejudice.”

Assuming without deciding that the first two factors have been met, (an error is plain when it “contravenes case la w, a rule, or a standard of conduct”), we conclude that the third factor has not been sa tisfied for two reasons.

Though the Caron test has been called into question, d 294, 302 (Minn. 2006), if the alleged prosecutorial misconduct was harmless beyond a reasonable doubt, then there is no need to address the standard for less serious misconduct.

d 294, 302 (Minn. 2006).

The American Bar Association (ABA) has established standards of conduct for prosecutors, and the Minnesota Supreme Court has stated, “We expect that prosecutors, as well as defense counsel, are aware of our case law proscribing particular conduct as well as the standards of conduct prescribed by the ABA.” State v. Ramey , (discussing the ABA standards for prosecutors and defense counsel).

see also State v. Smith , (“When a defendant fails to object at trial, the forfeiture doctrine gene rally precludes appellate relief.” (citation omitted) (internal quotation marks omitted)); –79 (Minn. 2015).

“Prosecutors have an affirmative obligation to ensure that a defendant receives a fair trial ” and are obliged “to guard the rights of the accused.” (quotation omitted).

7 Because eliciting plainly inadmissible testimony may constitute prosecutorial misconduct, see State v. Fields , the modified plain-error test therefore applies

( acknowledging that the supreme court’s power to reverse “prophylactically or in the interests of justice” comes from its power to supervise trial courts (quotation omitted)); n.6 (Minn. 2006) (stating that the court of appeals does not exercise supervisory powers that are reserved for the supreme court).

If the defendant meets this burden, the burden shifts, and the state must show “that the error did not affect the defendant’s substantial rights.” Id.

(citing State v. Ramey , ).

“An error is plain if it is ‘clear’ or ‘obvious’” by “‘contraven[ing] case law, a rule, or a standard of conduct.’” State v. Webster , (d 294, 302 (Minn. 2006).

An error is plain if it is clear or obvious, and an error is clear or obvious if it “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.”