In People v. Centeno (2014) 60 Cal.4th 659, the prosecution used descriptions of a state, suggesting that the state was California, even though some of the descriptions of California were incomplete and inaccurate. The prosecutor argued that, despite the incomplete and even inaccurate descriptions, it was clear beyond a reasonable doubt that the state described was California. (Id. at pp. 665-666.) The Supreme Court concluded this was prejudicial misconduct and reversed, even though the issue had been forfeited, because trial counsel's failure to object violated the defendant's right to counsel. (Id. at pp. 674-678.)