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To support his position, McKinney relies on State v. Williams

But Jackson has the burden of showing “that the group allegedly excluded is a ‘distinctive’ group in the community, that the group in question was not fairly represented in the venire, and that the underrepresentation was the result of a ‘systematic’ exclusion of the group in question from the jury selection process.”

In cases where the prosecutor was found to have impermissibly disparaged the de fense, the prosecutor had made statements that the type of defense offered was without merit, see 23 –49 (Minn. 1994), or that the defense theory is one that is commonly used in cases of the type before the jury.

d 538, 548-49 (Minn. 1994).

For example, a prosecutor may not suggest that the defendant raised a particular defense because it was the only defense that “might work.”

ever do; not, it’s at my house, but it isn’t. Appellant argues that the statement was im proper because it “urged the jurors to put themselves in [appellant]’s shoes and ask themselves whether they would [return] a rental car when it was due.” It is improper to request jurors to “look at their own experiences as proof that the defendant’s de fense is not credible.” State v. Williams

See Taylor v. Louisiana, 419 U.S. 522, 530 (1975); State v. Williams

was not fairly represented in the venire.” Griffin, d at 100 ().

consented was only being offered because “nothing else [would] work.” (holding that prosecutors may not belittle a defense in the abstract or suggest a defendant raised a particular defense because it was the only defense that “might work”).

Examples of belittlement include challenging a defense in the abstract or suggesting that the defendant is asserting a particular defense because it is the only defense that "might work," State v. Williams , , 549 (Minn. 1994).

Citing State v. Williams , -48 (Minn. 1994), Stauffer contends that a police officer “cannot testify about typical behaviors of criminals and claim that a defendant’s behavior meets that criteria to imply his guilt of the offense.” This argument is unavailing for two reasons.

(stating that a criminal defendant is not guaranteed “a jury of a particular composition”).

(quotation omitted ); see State v. Yang , (an alyzing “gang affiliation” as a form of character evidence); State v. Williams , -48 (Minn. 1994) (evaluating “drug courier profile evidence” as character evidence).

The supreme court has held that “attempting to elicit 5 or actually eliciting clearly inadmissible evidence may constitute misconduct.2 Fields, d at 782; (determining that eliciting inadmissible evidence was prosecutorial misconduct).

But the prosecutor may not request that the jurors “put themselves in the shoes of the victim,” or “look at their own experiences as proof that the defendant’s defense is not credible,”

(“[A] police officer testifying in a criminal case may not, under the guise of explaining 5 how the investigation focused on defendant, relate hearsay statements of others.” (quotations omitted)); State v. Williams , (noting that “it is unlikely that the jury did not consid er the evidence as su bstantive evidence of defendant’s guilt” despite the prosecutor’s explanation that it was presented only to provide context to the officer’s actions).

” See State v. Williams , -49 (Minn. 1994); (concluding that the prosecutor improperly argued: “What do you typically hear about a rape case?

The nature of the state’s evidence is somewhat similar to drug -courier profile evidence, which the supreme court has said “seems akin to character evidence.” (quotation omitted).

the supreme court held that evidence of a “drug courier profile” (i.e., a composite of certain behaviors and characteristics common to people who transport drugs) was “clearly and plainly inadmissible” to prove that the defendant was guilty of possession of cocaine with intent to sell.

103(d); see also, d 538, 544 (Minn. 1994); cf. Minn. R. Crim.

v. Perry, -97 (Minn.1997); -44 (Minn.1994).

We have long been committed “to insuring] that the systems used are increasingly inclusive in the hope that the faces of the people in the jury room will soon mirror the faces of the people in the community at large.” see Hennepin Cnty.

For ex *539 ample, we reversed a conviction based on the “cumulative effect of three instances of prosecutorial misconduct.” ().

“A drug courier profile is an informally compiled abstract of characteristics thought typical of persons carrying illicit drugs.” .

Although appeals to common sense are permitted, see Starkey, d at 927 , a prosecutor may not urge the jurors to look at their own experiences to determine whether a defense is credible

we held that it is improper during closing arguments for the State to invite jurors to speculate as to the motivation for a defendant to try the case a specific way.