State v. Gillies
In State v. Gillies, 135 Ariz. 500, 510, 662 P.2d 1007, 1017 (1983), defense counsel argued in closing "that the state had accumulated and presented to the jury physical evidence which had no real connection to the defendant." 135 Ariz. at 510, 662 P.2d at 1017.
In rebuttal, the prosecutor stated: "All other evidence points to the defendant.
His cigarette on the rock on top of her body, as in the car, all the physical evidence that had been taken from the vehicle, all her property, all other evidence points to the defendant, . . . and he didn't try to explain that because he couldn't."
The Arizona Supreme Court concluded that the prosecutor's comments were "fair rebuttal" to defense counsel's argument. Id.