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defendants as applies to the State, and, accordingly, defense counsel should not argue that a particular religion requires the imposition of a sentence other than death . This Court has acknowledged that ‘[i]t is difficult to draw a precise line between religious arguments that are acceptable and those that are objectionable....’ Id. In light of this difficulty, some discretion must be afforded to trial courts in determining whether a particular argument, whether made by the State or by a defendant, tends to urge jurors’ compliance with some religious mandate in potential exclusion of their duty to consider all applicable sentencing alternatives. This Court finds that the trial court did not exceed this limited discretion in evaluating King’s argument about what Jesus might do.” Pace v. State, 271 Ga. 829, 524 S.E.2d 490 (December 3, 1999). Defendant’s convictions for capital murder, rape, and related offenses affirmed; prosecutor’s sentencing phase closing argument was not objectionable based on religious references: “The prosecutor told the jury that he anticipated that Pace's counsel would tell a New Testament parable about forgiveness and mercy, and he argued that there should not be forgiveness unless there is remorse. The prosecutor also stated in a different part of his argument that some of the jurors had said they believed in an ‘eye for an eye’ during voir dire and that the State was now asking for an eye for an eye. Pace did not object to any religious references by the prosecutor, and the prosecutor did not argue that divine law called for a death sentence. The religious references in this case do not rise to the level of the inflammatory argument made in Hammond v. State, 264 Ga. 879(8)(c), 452 S.E.2d 745 (1995).” 7. CONTENT – BURDEN SHIFTING Singleton v. State, 326 Ga.App. 609, 757 S.E.2d 211 (March 27, 2014). Armed robbery and related convictions affirmed; prosecutor’s closing argument that “the evidence was unrefuted” wasn’t impermissibly burden shifting, citing Turner v. State , 199 Ga.App. 836, 838(4), 406 S.E.2d 512 (1991). Flewelling v. State, 300 Ga.App. 505, 685 S.E.2d 758 (October 16, 2009). At defendant’s trial for aggravated child molestation and statutory rape, prosecutor’s argument was not burden shifting: “And as an adult man, he is supposed to take on this extra colloquial responsibility if he finds himself in a situation where a fifteen year old is making advances at him. He has got to stop it. He has to withdraw from that situation. He has got to make sure that that child knows there is not going to be anything going on between the two of them. And if he does not, he has broken the law.” “The challenged argument was a continuation of the state's theme that ‘grown men can't have sex with children under the age of sixteen’ and did not shift the burden of proof to Flewelling. When considered in its total context, the argument properly addressed evidence that the sexual activity was consensual [fn] and was a proper rebuttal to Flewelling's closing argument that he ‘ma[de] a bad decision as to how to deal with 15 year olds.’” Sampson v. State, 282 Ga. 82, 646 S.E.2d 60 (June 4, 2007). No improper burden shifting: “Sampson cites comments, inter alia, that the case was brought to superior court; that the trial was taking place because Sampson ‘insisted on a jury trial’; that Sampson was entitled to an attorney and the attorney was responsible to put forth any defense or challenge any evidence that he might wish to; and that in defense counsel’s opening statement, the jury never heard, ‘He didn’t do it.’ Such comments did not, as Sampson urges, clearly imply that Sampson had to testify, that he had the burden of proving his innocence, and that by not testifying, he did not meet that burden.” Scott v. State, 281 Ga. 373, 637 S.E.2d 652 (November 20, 2006). “During closing argument, the State called the jury’s attention to Scott’s sole witness, noted that Scott did not have to present any evidence, and said: ‘in a murder case, if you are going to put something up ... what are you going to put up? Well, you are going to put up the best piece of evidence you’ve got, right?’ Scott objected, stated that he wished to make a motion, and the court excused the jury. Scott then argued that the argument was an attempt to shift the burden of proof to him. The court did not err in denying Scott’s motion for mistrial. See Johnson v. State, 271 Ga. 375, 383(15)(a) (519 S.E.2d 221) (1999) ( rejecting the contention that the State’s ‘make them explain’ argument was burden shifting ).” Duffy v. State, 271 Ga.App. 668, 610 S.E.2d 620 (February 16, 2005). Prosecutor argued in closing that bullet shells found at the scene matched defendant’s gun, but that defendant’s gun itself was missing, and “that speaks louder than anything else in this case. That screams out the defendant’s guilt.” Defense complains this argument was burden-shifting and commented on his right to remain silent. Held, trial court properly denied mistrial: “ ‘The State’s comments were not directed at the defendant’s decision not to testify; instead, they were directed at defense counsel’s failure to rebut or explain the State’s evidence . [Cit.]; Ingram v. State, 253 Ga. 622(8), 323 S.E.2d 801 (1984) (while a prosecutor may not comment on a defendant’s failure to testify, he may argue that evidence of guilt has not been contradicted or rebutted).’ Johnson v. State, 271 Ga. 375, 383(15)(a), 519 S.E.2d 221 (1999). Given that the State’s comment in this case
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