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In other words, if an appellant establishes that a district court committed two or more procedural errors, none of which individually requires a new trial, the appellant nonetheless may be “entitled to a new trial if the errors, when taken cumulatively, had the effect of denying appellant a fair trial.” (quotation omitted).

In State v. Jackson , the supreme court determined that expert testimony about general aspects of gang culture, such as the role of respect, was admissible “[b]ecause jurors are unlikely to be familiar with gang culture” and such testimony can be “helpful to establish the ‘for the benefit of a gang’ element and to explain the state’s theory of motive.”

“If any prong of the test is not met, the claim fails.”

“If any prong of the test is not met, the claim fails.”

“If any prong of the test is not met, the claim fails.”

“If any prong of the test is not met, the claim [of error] fails.”

“If any prong of the test is not met, the claim fails.”

(“Because neither this court nor the federal courts have conclusively resolved this issue, we cannot say that the prosecutor ‘contravene[d] case law, a rule, or a standard of conduct.’ ” (quoting Ramey, d at 302)); (explaining that to satisfy the second prong of the plain-error test, “the error must be plain at the time of the appeal”); see also United States v. Whab, 355 F.3d 155, 158 (2d Cir. 2004) (“Certainly, an error cannot be deemed ‘plain,’ in the absence of binding precedent, where there

(“The sentence for first-degree premeditated murder is not determined using the sentencing guidelines.”).

errors, when taken cumulatively, had the effect of denying appellant a fair trial.” (quotation omitted).

errors, when taken cumulatively, had the effect of denying appellant a fair trial.” (quotation omitted)).

in support of this argument.

State v. Jackson , (“We emphasize .

Even so, appellate courts have “discretion to consider an error not objected to at trial if it is plain error affecting substantial rights.” see also Minn. R. Crim.

In ot her words, if an appellant establishes that a district court committed tw o or more procedural errors, none of which individually requires a new trial, the appe llant nonetheless may be entitled to a new trial “if the errors, when taken cumulatively, had the effect of denying appellant a fair trial.” (quotation omitted).

fits within those limits because “the state may argue that certain witnesses were or were not credible.”

Appellant argues that these instructions are erroneous because they did not require the jury to find that appellant used force to overcome resistance to “the taking or carrying away of” A.W.’s car.3 “An error is plain if it is clear or obvious.” (quotation omitted).

Nor may a prosecutor “appea l to the passions and prejudices of the jury or otherwise seek to distract the jury from its proper role of deciding whether the state has met its burden of proof.” State v. Jackson

*311 State v. Jackson , , 698 (Minn. 2006).

Minnesota appellate courts have upheld the admissio n of expert testimony in circumstances similar to here .

tor committed misconduct by offering inadmissible evidence “has imposed on himself a higher threshold than plain error,” which would apply to a claim that the district court erred by failing to exclude unobjected-to evidence, and “must also show that the state had no good-faith basis to argue for admissibility and elicited the testimony knowing that it was inadmissible.” (Hanson, J., concurring).

It is “improper for a prosecutor to intentionally elicit inadmissible and highly preju dicial testimony.”

(noting that this court should “consider the closing argument as a whole rather than focus on particular phrases or remarks that may be taken out of context or given undue prominence” (quotations omitted)).

see also State v. Jackson , -701 (Minn. 2006) (Hanson, J., dis senting).

When examining alleged prosecutorial misconduct in the context of a closing argument , we “consider the closing argument as a whole rather than focus on particular phrases or remarks.” d 681, 694 (Minn. 2006) (quotations omitted).

Moreover, “the error must be plain at the time of the appeal.”

When determining whether a prosecutor committed misconduct during a closing argument, appellate courts “consider the closing argument as a whole rather than focus[ing] on particular phrases or remarks.” (quotation omitted).

When determining whether a prosecutor committed misconduct during a closing argument, this court “consider[s] the closing argument as a whole rather than focus[ing] on particular phrases or remarks.” (quotations omitted).

In analyzing whether a prosecutor committed misconduct during closing argument, this court considers “the closing argument as a whole rather than focus[ing] on particular phrases or remarks that may be taken out of context or given undue prominence.” (quotations omitted).

“If any prong of the [plain-error] test is not met, the claim fails.”

(quotations omitted) (noting that this court should consider “the closing argument as a whole rather than focus on 7 particular phrases or remarks that may be taken out of context or given undue prominence”).

(noting that this court should consider “the closing argument as a whole rather than focus on particular phrases or remarks that may be taken out of context or given undue prominence”).

We have “never categorically prohibited the use of gang expert testimony.”

(recognizing that evidence about a defendant’s involvement in a gang, including expert testimony about gang culture and a particular gang, was admissible because it “had significant probative value” to an essential element of the crime under section 609.229, and that exclusion of such evidence wo

(“If any prong of the [plain-error] test is not met, the claim fails.”).

d 681, 698 (Minn. 2006) (“An appellant is entitled to a new trial if .

Inadmissible Other-Crimes Testimony “It is improper for a prosecutor to intentionally elicit inadmissible and highly prejudicial testimony.”

Prosecutorial misconduct When determining whether prosecutorial misconduct occurred during a closing argument, we “consider the closing argument as a whole rather than focus[ing] on particular phrases or remarks that may be taken out of context or given undue prominence.” (quotations omitted).

may be taken out of context or given undue prominence.” (quotation omitted).

(“A prosecutor may not personally endorse the credibility of a witness or impliedly guarantee a witness’s truthfulness.”); (holding that the statement “[T]he state believes [the witness] is very believable” constituted impermissible vouching); bu

(“If any prong of the [plain-error] test is not met, the claim fails.”).

When determining whether there was prosecutorial misconduct during a closing argument, we consider “the closing argument as a whole rather than focus[ing] on particular phrases or remarks that may be taken out of context or given undue prominence.” d 681, 694 (Minn. 2006) (quotations omitted).