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See generally State v. Smith , (affirming the exclusion of evidence that risked creating a “trial-within -a- trial” that “would misdirect the jury away from the key inquiry” (quotation omitted)).

When evaluating prosecutorial misconduct during a closing argument, appellate courts review “the closing argument as a whole” instead of focusing on “selected phrases and remarks.” State v. Smith , (quotations omitted).

When analyzing a claim of prosecutorial misconduct during closing argument, we consider the argument “as a whole,” not “selected phrases and remarks.” d 310, 335 (Minn. 2016) (quotation omitted).

It is misconduct for the prosecutor to “intentionally misstate the evidence or mislead the jury as to the inferences it may draw.” (quotation omitted).

-32 (Minn. 2016) (affirming exclusion of evidence that risked creating a “trial-within-a-trial” that “would misdirect the jury away from the key inquiry” (quotation marks omitted)).

See, d 310, 330 (Minn. 2016) (describing “routine evidentiary rulings and matters traditionally addressed during private bench conferences” as “routine administrative proceedings”); Wohlfeil v. Murray Mach., Inc., -75 (Minn. App. 1984) (analyzing an evidentiary issue discussed at two bench conferences durin

“Cumulative error exists when the cumulative effect of the errors and indiscretions, none of which alone might have been enough to tip the scales, operate to the defendant’s prejudice by producing a biased grand jury.” 326 (Minn. 2016) (quotation omitted).

ssues, or mislead the jury.” Walker’s opening-the-door argument on appeal rests on his contention that R.C.’s mother’s testimony “went beyond typical ‘spark of life’ testimony.” “Spark of life” evidence consists of biographical testimony about the victim to show that “[t]he victim was not just bones and sinews covered with flesh, but was imbued with the spark of life.” -26 (Minn. 2016) (d 204, 207 (Minn. 1985)).

Under the statute, an offender “bears the initial burden of production to challenge a restitution request.”

When analyzing a claim of prosecutorial misconduct during closing argument, we consider the argument “as a whole,” not “selected phrases and remarks.” d 310, 335 (Minn. 2016) (quotation omitted).

It is improper for a prosecuting attorney “intentionally to misstate the evidence or mislead the jury as to the inferences it may draw.” (quotations omitted).

In other words, appellate courts “must generally consider only those issues that the record shows were presented and considered by the trial court in deciding the matter before it.” d 310, 335 (Minn. 2016) (quotations omitted).

-32 (Minn. 2016) (affirming exclusion of evidence that risked creating a “trial-within-a-trial” that “would misdirect the jury away from the key inquiry” (quotation marks omitted)).

District courts have “broad discretion in weighing probative value against unfair prejudice.”

When we review for “prosecutorial misconduct during a closing argument, we look to the closing argument as a whole, rather than to selected phrases and remarks.” (quotation omitted).

bing a witness as “aggressive” and “huge and burly”; and (4) vouch ing for the credibility of the state’s witnesses by prefacing a comment about witnesses clarifying questions with “I submit to you—or the state submits to you.” When analyzing a claim of prosecutorial misconduct during closing argument, we review the argument “as a whole,” not “selected phrases and remarks.” (quotation omitted).

It is unprofessional conduct, however, for the prosecutor intentionally to misstate the 8 evidence or mislead the jury as to the inferences it may draw.” d 310, 335 (Minn. 2016) (quotation omitted).

12 “Spark of life” evidence consists of biographical testimony about the victim to show that “[t]he victim was not just bones and sinews covered with flesh, but was imbued with the spark of life.” –26 (Minn. 2016) ().

“Prosecutors are allowed to argue all reasonable inferences from evidence in the record.” (citation omitted) (internal quotation marks omitted) .

Introducing such evidence at trial would likely have turned a criminal trial into a custody battle, and the Minnesota Supreme Court previously affirmed a district court’s decision to exclude certain disputed evidence because admitting the evidence would “misdirect the jury away from the key inquiry.” (quotation omitted) .

Moreover, “[i]f a trial court’s evidentiary ruling is determined to be erroneous, and the error reaches the level of a constitutional error, such as denying the defendant the right to present a defense, our standard of review is whether the exclusion of evidence was harmless beyond a reasonable doubt.” (citation omitted) (internal quotation marks omitted).

Nor may a lawyer “misstate the evidence or mislead the jury as to the inferences it may draw.” (quotation omitted).

When analyzing a claim of prosecutorial misconduct during closing argument, we consider the argument “as a whole,” not “selected phrases and remarks.” (quotation omitted).

6 If an evidentiary ruling reaches the level of a constitutional error, the standard of review is whether the exclusion of the evidence was “harmless beyond a reasonable doubt.” (quotation omitted).

(explaining that due process requires that every defendant be afforded a meaningful opportunity to present a complete defense).

d 310, 335 (Minn. 2016).

6 “When evaluating prosecutorial misconduct during a closing argument, [an appellate court] look[s] to the closing argument as a whole, rather than to selected phrases or remarks.” (quotation omitted).

17 Statements Regarding the Evidence “Prosecutors are allowed to argue all reasonable inferences from evidence in the record.” (quotation omitted).

court charged with the affirmative obligation to achieve justice and fair adjudication, not merely convictions.” d 777, 782 (Minn. 2007) “A prosecutor engages in prosecutorial misconduct when the prosecutor violates clear or established standards of conduct, e.g., rules, laws, orders by a district court, or clear commands in this state’s case law.” -35 (Minn. 2016) (quotation omitted).

Every defendant must be provided the opportunity “to present a complete defense.” (citations omitted).

“Prosecutors are allowed to argue all reasonable inferences from evidence in the record.” (quotation omitted).

(prosecutors may argue all reasonable inferences from evidence in the record).

ur t charged with the affirmative obligation to achieve justice and fair adjudication, not merely convictions.” d 777, 782 (Minn. 2007) “A prosecutor e ngages in prosecutorial misconduct when the prosecutor violates clear or established standards of conduct, e.g., rules, laws, orders by a district court, or clear commands in this state’s case law.” -35 (Minn. 2016).

“Due process requires that every defendant be afforded a meaningful opportunity to present a complete defense.” State v. Smith , (quotations omitted).