C&F accuses California’s Second Appellate District of basically sanctioning quite egregious prosecutorial misconduct. True enough, in People v. Zurinaga, the prosecutor does many improper things. The panel goes on and on about how what he did was wrong. But, the panel affirms the conviction anyway, sending a clear message to prosecutors (that the First says as well): there are no limits to what you juries, because the courts will never reverse your convictions, doing its very best to find harmless error. Go ahead! No limits! Supervisors: no need to keep an eye on your underlings. They can so whatever they want, and say whatever they want. So long as they do it in front of a jury!