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Under the modified plain-error standard of review, the burden is on the defendant to demonstrate both that an error occurred and that the error was plain; if the defendant demonstrates that the prosecutor committed plain error, the burden shifts to the state to “demonstrate lack of prejudice; that is, the misconduct did not affect substantial rights.”

5 standard of conduct.” State v. Ramey , (M inn.

Usually this is shown if the error contravenes case law, a rule, or a standard of conduct.” State v. Ramey , (quotation omitted).

Compare State v. Yang , (reviewing objected-to evidence for harmless error) -98 (Minn. 2006) (reviewing for plain error when defendant fails to object at trial).

“Prosecutors have an affirmative obligation to ensure that a defendant receives a fair trial, no matter how strong the evidence of guilt.”

See State v. Ramey , (holding that appellate courts review unobj ected-to prosecutorial miscon duct under a modified plain- error test).

(holding “that appellate courts should use the plain error doctrine when examining unobjec ted-to prosecutorial misconduct”).

A prosecutor has “an affirmative obligation to ensure that a defendant receives a fair trial, no matter how strong the evidence of guilt.” .

To satisfy this burden, the State must show “that there is no reasonable likelihood that the absence of the misconduct in question would have had a significant effect on the verdict of the jury.” (citati on omitted) (internal quotation marks omitted).

Error that Was Plain 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.’” d 782, 787 (Minn. 2017) ().

“Prosecutors have an affirmative obligation to ensure that a defendant receives a fair trial, no matter how strong the evidence of guilt.”

And if a defendant fails to object to procedural error at trial, the “ unobjected-to error can be reviewed only if it constitutes plain error affecting substantial rights.”

n. 4 (Minn. 2006) (“Our decision today leads us to conclude that the Caron two-tiered standard is no longer applicable to cases involving unobjected-to prosecutorial misconduct.

“On appeal, an unobjected -to error can be reviewed only if it constitutes plain error affecting substantial rights.” (citing Minn. R. Crim.

State v. Ramey , -98 (Minn. 2006).

Because Garza did not object at trial, we consider whether there is “(1) error, (2) that is plain, and (3) affects substantial rights.”

As Reed did not object at trial, this court applies a modified plain -error test to the alleged misconduct and considers whether there is “(1) error, (2) that is plain, and (3) affects substantial rights.” State v. Ramey

Because appellant did not object at trial, we apply the modified plain-error test and consider whether there is “ (1) error, (2 ) that is plain, and (3) affects substantial rights.” 1