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An offense is necessarily included in a greater offense if “it is impossible to commit the greater offense without committing the lesser offense.” Bertsch, d at 664 (quotation omitted); (“If, after comparing the elements of each offense, a person can commit the greater offense, as legally defined, without committing the lesser offense, as legally defined, the lesser offense is not necessarily included within the greater offense.” (quotation omitted)).

(explaining that aggravated robbery without theft is assault).

to discern how this remark bears on the burden of proof at all.”

“In analyzing whether an offense is a lesser included offense, the court mu st look at the statutory elements of the relevant offenses rather than at the facts of a particular case.” -81 (Minn. 1985); (citing Coleman for this premise).

State v. Coleman , -81 (Minn. 1985).

The supreme court has held that “ misstatements of the burden of proof are highly improper and constitute prosecutorial misconduct.”

(citing State v. Nunn , ).

“[M]isstatements of the burden of proof are highly improper and constitute prosecutorial misconduct.”

“[M]isstatements of the burden of proof are highly improper and constitute prosecutorial misconduct.”

But a prosecutor’s “misstatements of the burden of proof are highly improper and constitute prosecutorial misconduct.”

“[M]isstatements of the burde n of proof are highly imprope r and constitute prosecutorial misconduct.”

–88 (Minn. App. 2010), review denied (Minn. June 29, 2010) (applying Coleman).

“[M]isstatements of the burden of proof are highly 7 improper and constitute prosecutorial misconduct.”

Thus, theft is a lesser included offense of aggravated robbery.” (citation omitted); (agreeing with Nunn’s reasoning that theft “is a lesser included offense *188 of aggravated robbery”).

-54 (Minn.1994); alluding in argument to the defendant’s exercise of the right not to testify, -51 (Minn.1997), or to the defendant’s failure to call witnesses, misstating the presumption of innocence, Salitros, d at 818 , or the burden of proof, interjecting the prosecutor’s personal opinion about the veracity of witnesses, inflaming the passions and prejudices of the jury, Porter, d at 363-64 ; disparaging the defendant’s defense to the charges, (M

He requested instruction on bestiality, but court held that theory of defense was subsumed by instructions on elements of charged crime); (defendant not entitled to theft by swindle instruction because that crime is not lesser-included offense of aggravated robbery); Ruud, d at 578-79 (in trial for theft and presenting false claim to public body, defendants not entitled to instruction on defense of reliance on accountant where

charged; and in fourth incident, identity was not in doubt); *434 -97 (Minn.1987) (holding that clear and convincing evidence that defendant committed acts alleged in six apparently uncharged Spreigl incidents existed when there was eyewitness testimony, there was no rebutting testimony, and the identity of the participants was not in doubt); -82 (Minn.1985) (affirming admission of evidence of defendant's participation in two other apparently uncharged robberies even though witness identificatio

(finding that comment made during closing weighed against overall strength of state’s case shows comments not likely to be prejudicial).

Failure to object ordinarily forfeits a criminal defendant’s right to review, although a defendant may obtain appellate review of and relief from plain errors affecting substantial rights if those errors had the effect of depriving the defendant of a fair trial.

-82 (Minn.1985) (upholding the trial court’s admission of other crime evidence despite some uncertainty in the witnesses’ identification of the defendant).