integrity bar in California

2025Dept. of Corporations v. SpeeDee Oil Change Systems, Inc. (1999) 20 Cal.4th 1135, 1145 .) “[U]ltimately the issue involves a conflict between a client’s right to counsel of his choice and the need to maintain ethical standards of professional responsibility. ‘The preservation of public trust both in the scrupulous administration of justice and in the integrity of the bar is paramount . . . . [The client’s recognizably important right to counsel of his choice] must yield, however, to considerations of ethics which run to the very integrity of our judicial process.’ ” (Comden v. Superior Court (

2025Dept. of Corporations v. SpeeDee Oil Change Systems, Inc. (1999) 20 Cal.4th 1135, 1145 .) “[U]ltimately the issue involves a conflict between a client’s right to counsel of his choice and the need to maintain ethical standards of professional responsibility. ‘The preservation of public trust both in the scrupulous administration of justice and in the integrity of the bar is paramount . . . . [The client’s recognizably important right to counsel of his choice] must yield, however, to considerations of ethics which run to the very integrity of our judicial process.’ ” (Comden v. Superior Court (

2026“It would be naive not to recognize that the motion to disqualify opposing counsel is frequently a tactical device to delay litigation. [Citation.] ‘[Judicial] scrutiny [is required] to prevent literalism from possibly overcoming substantial justice to the parties.’ [Citation.] However, ultimately the issue involves a conflict between a client’s right to counsel of his[, her, or their] choice and the need to maintain ethical standards of professional responsibility. ‘The preservation of public trust both in the scrupulous administration of justice and in the integrity of the bar is paramount .

2025Dept. of Corporations v. SpeeDee Oil Change Systems, Inc. (1999) 20 Cal.4th 1135, 1145 .) “[U]ltimately the issue involves a conflict between a client’s right to counsel of his choice and the need to maintain ethical standards of professional responsibility. ‘The preservation of public trust both in the scrupulous administration of justice and in the integrity of the bar is paramount . . . . [The client’s recognizably important right to counsel of his choice] must yield, however, to considerations of ethics which run to the very integrity of our judicial process.’ ” (Comden v. Superior Court (

2026(People v. Spector (2011) 194 Cal.App.4th 1335, 1403 .) “A prosecutor commits misconduct if he or she attacks the integrity of defense counsel, or casts aspersions on defense counsel.” (People v. Hill (1998) 17 Cal.4th 800, 832 .) “However, ‘the prosecutor has wide latitude in describing the deficiencies in opposing counsel’s tactics and factual account.’” (People v. Winbush (2017) 2 Cal.5th 402, 484 (Winbush).) “We review claims of prosecutorial misconduct under an abuse of discretion standard [citations], asking whether there is a reasonable likelihood the jury construed the remarks in an ob

2024The legal authority invoked by Lattin is that “[a] prosecutor commits misconduct if he or she attacks the integrity of defense counsel, or casts aspersions on defense counsel.” (People v. Hill (1998) 17 Cal.4th 800, 832 .) It is also misconduct for a prosecutor to characterize the defense bar in general as comprised of liars or to accuse defense counsel in a particular case of lying to the jury.

2025Dept. of Corporations v. SpeeDee Oil Change Systems, Inc. (1999) 20 Cal.4th 1135, 1145 .) “[U]ltimately the issue involves a conflict between a client’s right to counsel of his choice and the need to maintain ethical standards of professional responsibility. ‘The preservation of public trust both in the scrupulous administration of justice and in the integrity of the bar is paramount . . . . [The client’s recognizably important right to counsel of his choice] must yield, however, to considerations of ethics which run to the very integrity of our judicial process.’ ” (Comden v. Superior Court (

2025Dept. of Corporations v. SpeeDee Oil Change Systems, Inc. (1999) 20 Cal.4th 1135, 1145 .) “[U]ltimately the issue involves a conflict between a client’s right to counsel of his choice and the need to maintain ethical standards of professional responsibility. ‘The preservation of public trust both in the scrupulous administration of justice and in the integrity of the bar is paramount . . . . [The client’s recognizably important right to counsel of his choice] must yield, however, to considerations of ethics which run to the very integrity of our judicial process.’ ” (Comden v. Superior Court (

2025Co. (2003) 111 Cal.App.4th 698, 705 (Jessen).) “The paramount concern is the preservation of public trust in the scrupulous administration of justice and the integrity of the bar.” (Ibid.) “We review the trial court’s decision under the familiar abuse of discretion standard.” (Ibid.) In doing so, we give deference to the trial court’s factual findings, so long as they are supported by substantial evidence.

2023Co. (2003) 111 Cal.App.4th 698, 710 .) “In determining whether a conflict of interest requires disqualification,” the “ ‘paramount concern must be to preserve public trust in the scrupulous administration of justice and the integrity of the bar.

2022There’s no evidence to support it.” 26 “ ‘ “A prosecutor commits misconduct if he or she attacks the integrity of defense counsel, or casts aspersions on defense counsel.” ’ ” (People v. Seumanu, supra, 61 Cal.4th at pp. 1336-1337; see also People v. Bemore (2000) 22 Cal.4th 809, 846 [“It is generally improper for the prosecutor to accuse defense counsel of fabricating a defense [citations], or to imply that counsel is free to deceive the jury”].) “Such attacks on counsel’s credibility risk focusing the jury’s attention on irrelevant matters and diverting the prosecution from its proper role o

2021Relevant Legal Principles “It is misconduct for the prosecutor in argument to impugn the integrity of defense counsel or to suggest defense counsel has fabricated a defense.” (People v. Cash (2002) 28 Cal.4th 703, 732 ; People v. Bemore (2000) 22 Cal.4th 809, 846 ; People v. Bain (1971) 5 Cal.3d 839, 847 .) To that end, it is improper for the prosecutor to characterize defense counsel as a liar or to accuse defense counsel as lying to the jury.

2014“Casting uncalled for aspersions on defense counsel directs attention to largely irrelevant matters and does not constitute comment on the evidence or argument as to inferences to be drawn therefrom.” (People v. Thompson (1988) 45 Cal.3d 86, 112 .) “ ‘A prosecutor commits misconduct if he or she attacks the integrity of defense counsel, or casts aspersions on defense counsel.’ (People 13 v. Hill (1998) 17 Cal.4th 800 , 832 . . . .) ‘If there is a reasonable likelihood that the jury would understand the prosecutor’s statements as an assertion that defense counsel sought to deceive the jury, mis

2013Kincaid and Wilkinson would have been called to testify if they “could even offer an outside possibility that [the detected abnormalities] might have an effect on behavior. . . . [f] But, no, what we’re going to do is put a neuropsychologist who didn’t even know how to read an MRI to try to leave you with the impression now [szc] this variant in the brain has something to do with behavior.” “A prosecutor commits misconduct if he or she attacks the integrity of defense counsel, or casts aspersions on defense counsel.” (People v. Hill, supra, 17 Cal.4th at p. 832 .) “[H]arsh and colorful attacks

2015We agree “the paramount concern . . . must be the preservation of public trust in the scrupulous administration of justice and the integrity of the bar.” (In re Complex Asbestos Litigation, supra, 232 Cal.App.3d at p. 586 .) Likewise we agree that an attorney must be recused after “[h]aving become privy to an opposing attorney’s work product.” (Shadow Traffic Network v. Superior Court, supra, 24 Cal.App.4th at p. 1081 .) But those tenets do not apply to the facts in this case.

2015We agree “the paramount concern . . . must be the preservation of public trust in the scrupulous administration of justice and the integrity of the bar.” (In re Complex Asbestos Litigation, supra, 232 Cal.App.3d at p. 586 .) Likewise we agree that an attorney must be recused after “[h]aving become privy to an opposing attorney’s work product.” (Shadow Traffic Network v. Superior Court, supra, 24 Cal.App.4th at p. 1081 .) But those tenets do not apply to the facts in this case.

2018Proc., § 128, subd. (a)(5) ; [citations].) Ultimately, disqualification motions involve a conflict between the clients' right to counsel of their choice and the need to maintain ethical standards of professional responsibility. [Citation.] The paramount concern must be to preserve public trust in the scrupulous administration of justice *702 and the integrity of the bar." ( SpeeDee Oil , supra , 20 Cal.4th at p. 1145 , 86 Cal.Rptr.2d 816 , 980 P.2d 371 .) Importantly, observed the SpeeDee Oil court, "judges must examine these motions carefully to ensure that literalism does not deny the partie

2018Proc., § 128, subd. (a)(5) ; [citations].) Ultimately, disqualification motions involve a conflict between the clients' right to counsel of their choice and the need to maintain ethical standards of professional responsibility. [Citation.] The paramount concern must be to preserve public trust in the scrupulous administration of justice *702 and the integrity of the bar." ( SpeeDee Oil , supra , 20 Cal.4th at p. 1145 , 86 Cal.Rptr.2d 816 , 980 P.2d 371 .) Importantly, observed the SpeeDee Oil court, "judges must examine these motions carefully to ensure that literalism does not deny the partie

2026“It is misconduct for the prosecutor in argument to impugn the integrity of defense counsel or to suggest defense counsel has fabricated a defense.” (People v. Cash (2002) 28 Cal.4th 703, 732 .) Considered in context, however, it is apparent that the prosecutor’s remarks were directed at appellant and the in-custody witnesses, not defense counsel.

2022As defendant accurately notes, it is misconduct for the prosecutor “to impugn the integrity of defense counsel or to suggest defense counsel has fabricated a defense,” (People v. Cash (2002) 28 Cal.4th 703, 732 ), or to make “personal attacks on the integrity of opposing counsel,” (People v. Espinoza (1992) 3 Cal.4th 806, 820 ), or to use “ ‘ “ ‘ “deceptive or reprehensible methods to attempt to persuade either the court or the jury,” ’ ” ’ ” (People v. Hill (1998) 17 Cal.4th 800, 819 ).

2025Dept. of Corporations v. SpeeDee Oil Change Systems, Inc. (1999) 20 Cal.4th 1135, 1145 .) “[U]ltimately the issue involves a conflict between a client’s right to counsel of his choice and the need to maintain ethical standards of professional responsibility. ‘The preservation of public trust both in the scrupulous administration of justice and in the integrity of the bar is paramount . . . . [The client’s recognizably important right to counsel of his choice] must yield, however, to considerations of ethics which run to the very integrity of our judicial process.’ ” (Comden v. Superior Court (

2025Dept. of Corporations v. SpeeDee Oil Change Systems, Inc. (1999) 20 Cal.4th 1135, 1145 .) “[U]ltimately the issue involves a conflict between a client’s right to counsel of his choice and the need to maintain ethical standards of professional responsibility. ‘The preservation of public trust both in the scrupulous administration of justice and in the integrity of the bar is paramount . . . . [The client’s recognizably important right to counsel of his choice] must yield, however, to considerations of ethics which run to the very integrity of our judicial process.’ ” (Comden v. Superior Court (

2015Were we nevertheless to overlook this procedural defect and address the merits, we would find error but no prejudice. “ ‘A prosecutor commits *1337 misconduct if he or she attacks the integrity of defense counsel, or casts aspersions on defense counsel.’ [Citations.] ‘In evaluating a claim of such misconduct, we determine whether the prosecutor’s comments were a fair response to defense counsel’s remarks’ [citation], and whether there is a reasonable likelihood the jury construed the remarks in an objectionable fashion [citation].” (People v. Edwards (2013) 57 Cal.4th 658, 738 [ 161 Cal.Rptr.3

2013“A prosecutor commits misconduct if he or she attacks the integrity of defense counsel, or casts aspersions on defense counsel.” (People v. Hill (1998) 17 Cal.4th 800, 832 [ 72 Cal.Rptr.2d 656 , 952 P.2d 673 ]; see People v. Frye (1998) 18 Cal.4th 894, 978 [ 77 Cal.Rptr.2d 25 , 959 P.2d 183 ] (Frye) [a prosecutor’s argument that denigrates defense counsel “directs the jury’s attention away from the evidence and is therefore improper”].) “In evaluating a claim of such misconduct, we determine whether the prosecutor’s comments were a fair response to defense counsel’s remarks” (People v. Young (

2024(People v. Samayoa (1997) 15 Cal.4th 795, 841 .) A prosecutor may give his or her opinion on the state of the evidence, vigorously attack the defense case, and focus on the deficiencies in defense counsel’s tactics and factual account. 6 (People v. Redd (2010) 48 Cal.4th 691, 735 .) “A prosecutor commits misconduct if he or she attacks the integrity of defense counsel, or casts aspersions on defense counsel.” (People v. Hill (1998) 17 Cal.4th 800, 832 .) “[W]hen the claim focuses upon comments made by the prosecutor before the jury, the question is whether there is a reasonable likelihood that

2016(See Seumanu, supra, 61 Cal.4th at p. 1337 [“[a] prosecutor may vigorously challenge the validity of any defense, and can characterize the testimony of a witness, including the defendant, as untruthful, but to state or imply that defense counsel has fabricated a defense is generally misconduct”]; People v. Redd (2010) 48 Cal.4th 691, 734 [“‘[a] prosecutor commits misconduct if he or she attacks the integrity of defense counsel, or casts aspersions on defense counsel’”]; People v. Hill, supra, 17 Cal.4th at p. 832 [“‘[a]n attack on the defendant’s attorney can be seriously prejudicial as an att

2024DISCUSSION “The authority of a trial court ‘to disqualify an attorney derives from the power inherent in every court “[t]o control in furtherance of justice, the conduct of its ministerial officers.” ’ ” (Cobra Solutions, supra, 38 Cal.4th at p. 846 .) Disqualification motions implicate conflicts between the client’s right to counsel of choice and the need to maintain ethical standards of professional responsibility, but the “ ‘paramount concern must be to preserve public trust in the scrupulous administration of justice and the integrity of the bar.’ ” (Ibid.) We review the trial court’s deci

2023Conduct, rule 1.6, subd. (a)), and this duty to preserve client confidences “survives the termination of the attorney’s representations.” (Cobra Solutions, supra, 38 Cal.4th at pp. 846-847.) Consequently, to maintain public trust in the administration of justice and the integrity of the bar, courts may disqualify an attorney (and the attorney’s firm) from representing a new client bringing claims against a former client if the former client disclosed to the attorney confidential information material to those claims.

2026It more broadly looks at whether there is a genuine likelihood the attorney’s obtaining of the opponent’s privileged information “would impact the outcome of the [litigation] and the public’s trust in both the scrupulous administration of justice and the integrity of the bar.” (McDermott, supra, 10 25 Cal.App.5th at p. 1121; see also Clark, supra, 196 Cal.App.4th at pp. 54–55; City of San Diego v. Superior Court 30 Cal.App.5th 457, 472 .) For example, even if it appears the privileged information would not be admissible at trial, a court should consider whether the information may give the att

2025Dept. of Corporations v. SpeeDee Oil Change Systems, Inc. (1999) 20 Cal.4th 1135, 1145 .) “[U]ltimately the issue involves a conflict between a client’s right to counsel of his choice and the need to maintain ethical standards of professional responsibility. ‘The preservation of public trust both in the scrupulous administration of justice and in the integrity of the bar is paramount . . . . [The client’s recognizably important right to counsel of his choice] must yield, however, to considerations of ethics which run to the very integrity of our judicial process.’ ” (Comden v. Superior Court (

2024(Western Continental Operating Co. v. Natural Gas Corp. (1989) 212 Cal.App.3d 752 , 761–762 [“Our courts have distinguished the rule against representing conflicting interests from the attorney-client evidentiary privilege noting that the former is broader than the latter”].) “The California Supreme Court has . . . repeatedly held that the disqualification rules are not merely intended to protect client confidences or other ‘interests of the parties’; rather, ‘[t]he paramount concern . . . [is] to preserve public trust in the scrupulous administration of justice and the integrity of the bar.’

2020(Fiduciary Trust Internat. of California v. Superior Court (2013) 218 Cal.App.4th 465, 475, 477, 481-485 (Fiduciary Trust).) It has long been recognized that, “where an attorney undertakes to advise two clients on a single matter or transaction . . . [that] later results in litigation, the attorney is precluded from representing either client.” (Civil Service Com. v. Superior Court (1984) 163 Cal.App.3d 70, 81 (Civil Service Com.).) “The California Supreme Court has . . . repeatedly held that the disqualification rules are not merely intended to protect client confidences or other ‘interests o

2020The argument may be vigorous as long as it amounts to fair comment on the evidence, which can include reasonable inferences, or deductions to be drawn therefrom. [Citations.]” (People v. Wharton (1991) 53 Cal.3d 522, 567 .) The prosecutor acts improperly when he or she misstates or mischaracterizes the evidence (People v. Avena (1996) 13 Cal.4th 394, 420 ), vouches for the credibility of a witness (People v. Dickey (2005) 35 Cal.4th 884 , 8 913-914), impugns the integrity of defense counsel or casts aspersions on defense counsel (People v. Edwards (2013) 57 Cal.4th 658, 738 ), misstates the ap

2020The argument may be vigorous as long as it amounts to fair comment on the evidence, which can include reasonable inferences, or deductions to be drawn therefrom. [Citations.]” (People v. Wharton (1991) 53 Cal.3d 522, 567 .) The prosecutor acts improperly when he or she misstates or mischaracterizes the evidence (People v. Avena (1996) 13 Cal.4th 394, 420 ), vouches for the credibility of a witness (People v. Dickey (2005) 35 Cal.4th 884 , 8 913-914), impugns the integrity of defense counsel or casts aspersions on defense counsel (People v. Edwards (2013) 57 Cal.4th 658, 738 ), misstates the ap

2022(People v. Talle (1952) 111 Cal.App.2d 650, 677 .) A prosecutor may properly comment “upon the failure of the defense to introduce material evidence.” (People v. Bradford (1997) 15 Cal.4th 1229, 1339 .) However, it is misconduct for a prosecutor to argue “defense counsel knew his client was guilty.” (People v. Seumanu (2016) 61 Cal.4th 1293, 1338 .) “A prosecutor commits misconduct if he or she attacks the integrity of defense counsel, or casts aspersions on defense counsel.” (People v. Hill (1998) 17 Cal.4th 800, 832 .) Our Supreme Court has rejected a claim of prosecutorial 30 misconduct whe

2022There’s no evidence to support it.” 26 “ ‘ “A prosecutor commits misconduct if he or she attacks the integrity of defense counsel, or casts aspersions on defense counsel.” ’ ” (People v. Seumanu, supra, 61 Cal.4th at pp. 1336-1337; see also People v. Bemore (2000) 22 Cal.4th 809, 846 [“It is generally improper for the prosecutor to accuse defense counsel of fabricating a defense [citations], or to imply that counsel is free to deceive the jury”].) “Such attacks on counsel’s credibility risk focusing the jury’s attention on irrelevant matters and diverting the prosecution from its proper role o

2021So there must be no knife.” It is of course improper for a prosecutor to attack the integrity of defense counsel, but in evaluating such claims we must determine whether the prosecutor’s remarks “were a fair response to defense counsel’s remarks.” (People v. Young (2005) 34 Cal.4th 1149, 1189 .) Viewed in their entirety and in context of the prosecutor’s rebuttal arguments on this subject, it is clear that the prosecutor’s comments were directed at undermining defense counsel’s efforts to convince the jury that, because police did not locate a knife in the area despite a thorough investigation

2013Impugning Defense Counsel Defendant argues the prosecutor improperly impugned defense counsel in his argument to the jury. “ ‘A prosecutor is allowed to make vigorous arguments and may even use such epithets as are warranted by the evidence, as long as these arguments are not inflammatory and principally aimed at arousing the passion or prejudice of the jury.’ [Citation.]” (People v. Young (2005) 34 Cal.4th 1149, 1195 [ 24 Cal.Rptr.3d 112 , 105 P.3d 487 ].) However, “[a] prosecutor commits misconduct if he or she attacks the integrity of defense counsel, or casts aspersions on defense counsel.

2025The Preservation of Public Trust Is Not Imperiled Lastly, on the record reviewed here, the public defender’s representation of Cain poses no risk to “ ‘the preservation of public trust in the scrupulous administration of justice and the integrity of the bar.’ ” (Rhaburn, supra, 140 Cal.App.4th at p. 1573 .) This is for three reasons.

2014(See Cornwell, at p. 75; People v. Lawley (2002) 27 Cal.4th 102, 146 ; People v. Clark (1993) 5 Cal.4th 950, 1001-1002 , disapproved on another ground in Doolin, at p. 421, fn. 22; see also Rhaburn v. Superior Court (2006) 140 Cal.App.4th 1566, 1577-1578 (Rhaburn) [discussing Supreme Court cases].) 13 In considering a motion to disqualify counsel, “the ‘paramount concern is the preservation of public trust in the scrupulous administration of justice and the integrity of the bar.’ [Citation.] On review, the standard is ‘abuse of discretion.’ [Citation.] The party resisting disqualification bear

2026That doesn’t mean that what he’s saying is reasonable.’ ” “ ‘A prosecutor commits misconduct if he or she attacks the integrity of defense counsel, or casts aspersions on defense counsel.’ [Citations.] ‘In evaluating a claim of such misconduct, we determine whether the prosecutor’s comments were a fair response to defense counsel’s remarks’ [citation], and whether there is a reasonable likelihood the jury construed the remarks in an objectionable fashion.” (People v. Edwards (2013) 57 Cal.4th 658, 738 ; see also People v. Herring (1993) 20 Cal.App.4th 1066, 1075 .) We generally agree with Tapi

2021And who better to kill Daniel Monge than the guy whose girlfriend Daniel Monge had talked trash about.” “‘A prosecutor commits misconduct if he or she attacks the integrity of defense counsel, or casts aspersions on defense counsel.’ [Citations.] ‘In evaluating a claim of such misconduct, we determine whether the prosecutor’s comments were a fair response to defense counsel’s remarks’ [citation], and whether there is a reasonable likelihood the jury construed the remarks in an objectionable fashion.” (People v. Edwards (2013) 57 Cal.4th 658, 738 .) “Improper vouching occurs when the prosecutor

2003Dept. of Corporations v. SpeeDee Oil Change Systems, Inc. (1999) 20 Cal.4th 1135, 1145 [ 86 Cal.Rptr.2d 816 , 980 P.2d 371 ] (SpeeDee Oil Change Systems); Metro Goldwyn-Mayer, Inc. v. Tracinda Corp. (1995) 36 Cal.App.4th 1832, 1838 [ 43 Cal.Rptr.2d 327 ].) The paramount concern is the preservation of public trust in the scrupulous administration of justice and the integrity of the bar.

2003Dept. of Corporations v. SpeeDee Oil Change Systems, Inc. (1999) 20 Cal.4th 1135, 1145 [ 86 Cal.Rptr.2d 816 , 980 P.2d 371 ] (SpeeDee Oil Change Systems); Metro Goldwyn-Mayer, Inc. v. Tracinda Corp. (1995) 36 Cal.App.4th 1832, 1838 [ 43 Cal.Rptr.2d 327 ].) The paramount concern is the preservation of public trust in the scrupulous administration of justice and the integrity of the bar.

2022(People v. Talle (1952) 111 Cal.App.2d 650, 677 .) A prosecutor may properly comment “upon the failure of the defense to introduce material evidence.” (People v. Bradford (1997) 15 Cal.4th 1229, 1339 .) However, it is misconduct for a prosecutor to argue “defense counsel knew his client was guilty.” (People v. Seumanu (2016) 61 Cal.4th 1293, 1338 .) “A prosecutor commits misconduct if he or she attacks the integrity of defense counsel, or casts aspersions on defense counsel.” (People v. Hill (1998) 17 Cal.4th 800, 832 .) Our Supreme Court has rejected a claim of prosecutorial 30 misconduct whe

2020(People v. Talle (1952) 111 Cal.App.2d 650, 677 .) “A prosecutor commits misconduct if he or she attacks the integrity of defense counsel, or casts aspersions on defense counsel.” (People v. Hill (1998) 17 Cal.4th 800, 832 .) “Casting uncalled for aspersions on defense counsel directs attention to largely irrelevant matters and does not constitute comment on the evidence or argument as to inferences to be drawn therefrom.” (People v. Thompson (1988) 45 Cal.3d 86 , 24 112.) The Supreme Court has rejected a claim of prosecutorial misconduct where the prosecutor observed during closing remarks th

2025(People v. Lamb (2024) 16 Cal.5th 400 , 435–436 (Lamb).) “The prosecution is given wide latitude during closing argument to make fair comment on the evidence, including reasonable inferences or deductions to be drawn from it.” (People v. Harris (2005) 37 Cal.4th 310, 345 .) A prosecutor commits misconduct, however, if she “ ‘attacks the integrity of defense counsel, or casts aspersions on defense counsel.’ ” (People v. Pearson (2013) 56 Cal.4th 393, 442 .) A defendant arguing prosecutorial misconduct must demonstrate that, when considering the whole argument and all jury instructions, there wa

2024Asserted Attacks on Defense Counsel’s Integrity “The prosecution is given wide latitude during closing argument to make fair comment on the evidence, including reasonable inferences or deductions to be drawn from it.” (People v. Harris (2005) 37 Cal.4th 310, 345 .) “ ‘A prosecutor commits misconduct if he or she attacks the integrity of defense 46 PEOPLE v. LAMB Opinion of the Court by Evans, J. counsel, or casts aspersions on defense counsel.’ ” (People v. Pearson (2013) 56 Cal.4th 393, 442 (Pearson).) “ ‘It is, of course, improper for the prosecutor “to imply that defense counsel has fabrica