J. JONES, Justice.
Sarah Kathleen Pearce appeals from her conviction of conspiracy to commit robbery, robbery, conspiracy to commit first degree kidnapping, first degree kidnapping, aggravated battery, and aiding and abetting attempted first degree murder. She contends that the district court (1) erred when it declined to allow her expert witness to testify on lineup procedures and the effect of such procedures on identifications, (2) erred by failing to instruct the jury regarding dangers inherent in eyewitness identification, and (3) violated her due process rights when it failed to admit the prosecutor’s arguments from co-defendants’ trials. The Court of Appeals concluded that the district court erred in failing to allow Pearce’s expert to testify, but that any error was harmless. The Court of Appeals affirmed her conviction. Pearce petitioned this Court for review and we granted it.
I.
FACTUAL AND PROCEDURAL SUMMARY
In the early morning hours of June 15, 2000, as Linda LeBrane was driving eastbound on Interstate 84, she was forced off the road by a vehicle carrying three men and one woman. The woman, later identified as Pearce by LeBrane and other witnesses who saw the group either before or after the attack, entered LeBrane’s vehicle and unlocked her driver’s side door. The three men, since identified as John David Wurdemann (John), Kenneth Wurdemann (Kenneth), and Jeremy Sanchez, along with Pearce, forced LeBrane from her vehicle and demanded money and drugs. John, Sanchez, and Pearce punched, struck, stabbed, and cut LeBrane with their fists and sharp instruments while Kenneth struck LeBrane with an aluminum baseball bat. The assailants took money and property from LeBrane, including a credit card, and transported her to a location on Farmway Road in Canyon County. LeBrane was again forced from the vehicle, beaten, stabbed, cut, and struck repeatedly before John and Sanchez set fire to her vehicle. The group left her lying in the dirt at the scene.
On March 13, 2003, Pearce was charged by indictment, which alleged that she was the female assailant. At trial, Pearce steadfastly contended she was not the woman involved. Her defense rested, in part, on the allegedly questionable ability of LeBrane to identify the female perpetrator. Evidence at trial indicated that prior to the attack LeBrane had smoked two marijuana cigarettes and was “loaded” by the time her car reached the [244]*244Caldwell area. Additionally, LeBrane lost her glasses during the attack. Although the point at which she lost them is not clear, she admitted being nearsighted and unable to see without them. In the course of the investigation, LeBrane incorrectly identified two different women in two separate photo lineups. Pearce was in neither of the photo lineups. When questioned at trial, LeBrane admitted that the first woman she identified was the one most resembling the composite picture created after the incident1 and that the second was the woman most resembling the actress who portrayed the female assailant in a television episode of America’s Most Wanted, which featured the crime. LeBrane eventually identified Pearce in the third lineup — a video lineup that did not have any persons from the two previous photo lineups.
The methods employed in showing LeBrane the photo and video lineups were called into question at trial. Robert Miles, a detective with the Canyon County Sheriffs Office and the primary investigator on the case, testified that he had never received any training on how to conduct a photo lineup. In addition, when Miles instructed LeBrane regarding the photo lineup, he told her to identify the person who “most closely resembled” the perpetrator rather than telling her to pick the perpetrator if she was in the lineup. In one photo lineup, after LeBrane identified one person who she was positive was the female assailant, Miles told LeBrane she had picked the wrong person. With respect to the video lineup, Miles notified LeBrane prior to her identification that the lineup contained a person of interest.
In addition to LeBrane, several other people who allegedly saw the four perpetrators near the time and place of the attack identified Pearce as the female in the group, both in lineups and eventually in court. Keith Mower, who encountered the group at a rest stop on the night of the attack, identified Pearce as the female accompanying the Wurdemann brothers and Sanchez, both in a video lineup and later at trial. Steve Rupert, a clerk at a motel where the perpetrators allegedly stopped after the attack, also identified Pearce in the video lineup and in court, as having been with the three men. Rupert’s son, Joseph, also identified Pearce in the video lineup and at trial as having been at the motel.
LeBrane complained the photo lineups made identification difficult, but that the video lineup was more helpful. During one of the photo lineups, she told the deputy, “I need to see these people in person. I need to see height. I need to see body movements. I need to see body language. I need to hear voices.” She repeated this concern during the investigation. Mr. Mower also testified that the video lineup was “much, much better” than the photo lineups, and that it was much easier to make an identification with the video lineup.
Pearce offered Dr. Charles Honts, a psychology professor at Boise State University, to testify as an expert regarding the reliability of eyewitness identification, including commentary on lineup procedures. The state moved to exclude the testimony of Dr. Honts prior to trial. The district court allowed Dr. Honts to testify as an expert witness, but limited his testimony to the characteristics of memory without relation to the identifications in Pearce’s case. Additionally, the court did not allow Dr. Honts to testify regarding lineup procedures and resulting identifications in general, finding he was not sufficiently qualified as an expert in this area, either as to his background or his knowledge of the facts of Pearce’s case.
Pearce also called Kenneth as a defense witness. Kenneth, who had confessed to his participation in the attack, had previously testified for the state at the trials of John and Sanchez, who were both convicted for their involvement. During Sanchez’ first trial,2 he testified that Pearce was not the woman involved, but at Sanchez’ second trial he testified he did not know whether she was the woman. At Pearce’s trial, Kenneth testi[245]*245fied on direct examination that he had never seen the female participant prior to the night of the attack and that he did not believe the woman was Pearce. The state then impeached Kenneth’s credibility on cross-examination, focusing on his dishonesty throughout the investigation of the crime and his potential motive to lie.
Following the state’s cross-examination of Kenneth, Pearce brought a motion to dismiss. She asserted a due process violation based on the state’s inconsistent treatment of Kenneth’s testimony for different defendants charged with the same crime. Pearce also moved to admit as admissions of a party opponent the closing arguments from Sanchez’ first trial, where the state asserted that the jury should believe Kenneth’s testimony, specifically that regarding Pearce, as well as the sentencing argument in Kenneth’s case. The district court denied both the motion to dismiss and the motion to admit the arguments. The jury subsequently found Pearce guilty of all charges except aiding and abetting arson.
On appeal to the Court of Appeals, Pearce asserted the district court erred in refusing to allow Dr. Honts to testify as to lineup procedures and resulting identifications, failing to instruct the jury about the weaknesses of eyewitness identifications, denying her motion to dismiss, and excluding arguments from prior proceedings. Finding the record insufficient to determine whether the exclusion of certain expert testimony by Dr. Honts was erroneous or whether any such error would have been prejudicial, the Court of Appeals issued an order for temporary remand, directing the district court to receive an offer of proof by Pearce as to the specific testimony that would have been proffered at trial by Dr. Honts if it had not been excluded by the trial court on the state’s motion in limine. The district court held an evidentiary hearing on the matter and such record was before the Court of Appeals for its consideration and for ours on review.
II.
ISSUES ON APPEAL
The following issues are presented for determination: (1) whether the district court erred by declining to allow Pearce’s expert witness to testify about lineup procedures and the effect of such procedures on identifications;- (2) whether the district court erred by failing sua sponte to instruct the jury as to the dangers inherent in eyewitness identifications; and (3) whether the district court erred in denying the motion to dismiss and the related motion to admit prior prosecution arguments.
A.
The district court did not abuse its discretion in excluding certain testimony of Dr. Honts.
Pearce argues the district court abused its discretion in finding that Dr. Honts lacked the necessary education, experience, and factual background, to testify about police lineup procedures and the effect of procedures on identifications. A trial court’s decision regarding the admission of expert testimony is reviewed for abuse of discretion. State v. Merwin, 131 Idaho 642, 645, 962 P.2d 1026, 1029 (1998). When determining whether the district court abused its discretion, we consider: (1) whether the lower court rightly perceived the issue as one of discretion; (2) whether the court acted within the boundaries of such discretion and consistently with any legal standards applicable to specific choices; and (3) whether the court reached its decision by an exercise of reason. McDaniel v. Inland Northwest Renal Care Group-Idaho, LLC, 144 Idaho 219, 221-22, 159 P.3d 856, 858-59 (2007).
To give expert testimony, a witness must first be qualified as an expert on the matter at hand. State v. Trevino, 132 Idaho 888, 895, 980 P.2d 552, 559 (1999). Idaho Rule of Evidence 702 is the appropriate test for measuring the reliability of evidence for expert testimony. Merwin, 131 Idaho at 646, 962 P.2d at 1030. “If scientific, technical, or other specialized knowledge will assist the trier of fact to understand the evidence or to determine a fact in issue, a witness qualified as an expert by knowledge, skill, experience or specialized knowledge may testify thereto in the form of opinion or otherwise.” Idaho [246]*246R. Evid. 702. Otherwise stated, the rule provides that qualified experts may testify in the form of an opinion only if their specialized knowledge will assist the trier of fact to understand the evidence or determine a fact in issue. There must be some demonstration that the witness has acquired, through some type of training, education or experience, the necessary expertise and knowledge to render the proffered opinion. State v. Eytchison, 136 Idaho 210, 213, 30 P.3d 988, 991 (Ct.App.2001). A witness may be qualified to render opinions about some things but not others. West v. Sonke, 132 Idaho 133, 139, 968 P.2d 228, 234 (1998). Once the witness is qualified as an expert, the trial court must determine whether such expert opinion testimony will assist the trier of fact in understanding the evidence. State v. Hopkins, 113 Idaho 679, 680-81, 747 P.2d 88, 89-90 (Ct.App.1987) (citing Sidwell v. William Prym, Inc., 112 Idaho 76, 80-81, 730 P.2d 996, 1000-01 (1986)). If the court concludes, as it did here, that the witness is not qualified to testify as to a particular matter, it is irrelevant whether such testimony would assist the trier of fact.
In this case, the district court first addressed whether the witness could testify about the reliability of eyewitness testimony, citing Idaho Rules of Evidence 401, 403, 702 and 704, and relying on numerous prior cases, including State v. Hoisington, 104 Idaho 153, 657 P.2d 17 (1983), State v. Alger, 115 Idaho 42, 764 P.2d 119 (Ct.App.1988), and State v. Hester, 114 Idaho 688, 760 P.2d 27 (1988). Using these rules and cases, the district court properly identified the legal standards applicable to this issue, and considered whether the proffered testimony would “assist the trier of fact.” The court concluded that Dr. Honts’ testimony concerning the various characteristics of memory and techniques related to memory was beyond the common experience of the jury and therefore admissible. The court also found that “Dr. Honts possessed the necessary qualifications, education, and experience to provide assistance and insight to the jury concerning these characteristics of memory.”
The district court, however, concluded that Dr. Honts could not testify about photo lineups, video lineups, and resulting identifications because it “was not persuaded,” based on the offer of proof, that Dr. Honts was qualified to testify on these particular issues. The district court applied the same legal standards on this issue as it did to the issue of whether Dr. Honts was qualified to testify regarding the characteristics of memory, and the reliability of eyewitness identifications generally. The court examined Dr. Honts’ qualifications and performed a thoughtful analysis of his ability to testify regarding the lineup issues:
The court further concludes, however, that Dr. Honts will not be permitted to testify concerning photo line-ups and video line-ups and resulting identification. First, the court is not persuaded, based on the offer of proof, that Dr. Honts possesses the necessary qualifications to testify concerning these issues. He testified that he has never participated in a police line-up, that he has never conducted a line-up, and that he has never interviewed or spoken with any of the witnesses in this ease whose testimony was relevant to those issues: Linda LeBrane, Keith Mower, Janine Waggoner, Steven Rupert, Officer Bob Miles, Officer Chris Smith, Officer Gary John, Dan Hally, or Carrie Parks. Further, he acknowledged having viewed only two of the many composite drawings involved in this case. Although he has viewed three video line-ups, he only did so for the first time two days ago. The court is not persuaded that Dr. Honts has the requisite factual information, background, and preparation concerning the eyewitness identification issues in this case to provide expert testimony on those matters. He has conducted no research in the area of photo line-ups or video lineups, and has never been qualified before to testify as a witness on these issues. Although he has testified previously in sixty-three (63) proceedings, the vast majority of his training, expertise, and court testimony has been concentrated in the area of polygraphs, an issue which is not presented in this case. The court is mindful that Dr. Honts teaches an upper division psychology class at Boise State University entitled “Psychology and the Law,” a course which covers a wide variety of topics of psychology related [247]*247to the legal profession and forensics; however, the court is not persuaded that he possesses sufficient expertise or experience in the area of photo line-up identification, video line-up identification, and recommended procedures for conducting lineups and photo spreads so as to meet the threshold necessary to qualify him as an expert for the purpose of analyzing the particular lineups in this case, the witness identifications arising therefrom, and offering his opinion as an expert to the jury. Additionally, any opinion Dr. Honts might offer concerning the particular witness identifications in this case, including, e.g., suggestability or tainted memories, begins to tread into impermissible ground: the credibility of the witness identification, which is the absolute province of the jury as the finders of fact.
The record amply supports the court’s reasoning here. The judge acted within her discretion in determining that Dr. Honts did not possess the necessary skill, experience, or specialized knowledge specific to lineup procedures. To the contrary, Dr. Honts’ area of expertise is actually in the field of polygraph testing, which was not at issue in this case. Dr. Honts had dealt only peripherally with lineup procedures and issues, having “talk[ed] about eyewitnesses, how to do lineups, how to conduct interviews,” in his Psychology and the Law class, and having heard about the .issue at conferences put together by the American Psychology-Law Society. Dr. Honts expressly admitted that he had not “specifically done” research in the area of eyewitness identification. Although he located a Department of Justice article entitled “Eyewitness Evidence Guide, A Guide for Law Enforcement,” he admitted he had not read the entire article. As counsel for the state noted at trial, Dr. Honts merely “acted as librarian” for the defense. The record reveals sufficient evidence to support the district court’s conclusion that Dr. Honts lacked academic or praetical experience specific to the area of lineup procedures.
Although there are grounds for concern regarding various aspects of the lineup procedures, particularly the photo lineups, and though it would likely have been helpful to have testimony from an expert on the matters the district court found Dr. Honts did not have the proper credentials upon which to opine, we cannot find that the court abused its discretion in excluding his testimony on these matters. An examination of the court’s decision clearly demonstrates the court viewed the issue as one of discretion, acted within the boundaries of its discretion, and reached its decision by an exercise of reason. The record adequately supports the court’s reasoning, which, logically flows from the legal standards it expressly relied upon in its decision.
B.
The district court did not err by failing sua sponte to instruct the jury as to the dangers inherent in eyewitness identification.
Pearce asserts the district court erred in failing to instruct the jury on the dangers inherent in eyewitness identification, arguing the jury should have been instructed on factors to consider in determining the accuracy of eyewitness identifications.3 Whether a jury has been properly instructed is a question of law. State v. Gleason, 123 Idaho 62, 65, 844 P.2d 691, 694 (1992). This Court exercises free review over questions of law. Id.
In charging the jury,, the court must state to them all matters of law necessary for their information. I.C. § 19-2132(a). Either party may present to the court any written charge and request that it be given. Id. “A defendant is entitled to an instruction where ‘there is a reasonable view of the evidence presented in the case that would support’ the theory.” State v. East[248]*248man, 122 Idaho 87, 90, 831 P.2d 555, 558 (1992). However, there is no duty for a trial court sua sponte to instruct the jury on every theory the defendant may have. “It is incumbent upon the defendant to submit a requested instruction or in some other manner apprise the trial court of the specific instructions requested.” Id.
Pearce failed to offer an instruction on the dangers inherent in eyewitness identification. This Court will not allow a defendant to appeal an instruction which was never offered at the trial level, unless that instruction constitutes a necessary matter of law whose omission would constitute fundamental error. State v. Anderson, 144 Idaho 743, 748-49, 170 P.3d 886, 891-92 (2007) (holding that even though new Idaho Crim. R. 30 expressly requires objection to preserve jury instruction issue on appeal, defendant may still appeal jury instructions, even without objection, where fundamental error occurs in instructions).
It is the defendant’s obligation to present his theories to the trial court, and the trial court is not under a duty to determine on which theories to instruct the jury. Eastman, 122 Idaho at 91, 831 P.2d at 559. A defendant may not claim error on appeal for a defense theory which does not constitute a necessary matter of law and for which no instruction was requested. The trial court did not err in failing sua sponte to instruct the jury on the inherent dangers of eyewitness identification.
C.
The district court did not err in denying the motion to dismiss.
At trial, Pearce called Kenneth to testify in her defense. Kenneth had previously pleaded guilty for his role in the attack and had testified as a state witness in the two trials of Jeremy Sanchez. At Sanchez’ first trial, Kenneth testified John and Sanchez were the other male assailants. Kenneth testified he did not know the female assailant, but that it was not Pearce. During Sanchez’ second trial, Kenneth testified consistently as to the male assailants but then stated that he did not know whether Pearce was the female involved. Finally, at Pearce’s trial, Kenneth again testified that he did not believe Pearce was the female assailant. The state attempted to impeach Kenneth’s credibility by using instances of his dishonesty throughout the investigation of the crime. However, the state had defended Kenneth’s credibility during the Sanchez trials, despite defense counsel’s similar attack on his veracity using essentially the same instances of dishonesty. Pearce moved to dismiss at the close of Kenneth’s testimony, claiming the state’s opposing positions about Kenneth’s credibility violated her constitutional right to due process.
When an appellant asserts the violation of a constitutional right, we give deference to the trial court’s factual findings unless those findings are clearly erroneous. State v. Henage, 143 Idaho 655, 658, 152 P.3d 16, 19 (2007). We exercise free review over the trial court’s determination as to whether constitutional requirements have been satisfied in light of the facts found. Id. The Due Process Clause guarantees every defendant the right to a trial comporting with basic tenets of fundamental fairness. Lassiter v. Dept. of Soc. Servs., 452 U.S. 18, 24-25, 101 S.Ct. 2153, 2158-2159, 68 L.Ed.2d 640, 647-648 (1981); Turner v. Louisiana, 379 U.S. 466, 471-72, 85 S.Ct. 546, 548-50, 13 L.Ed.2d 424, 428-29 (1965).
Pearce argues the state’s conduct in her trial is akin to that in Thompson v. Calderon, 120 F.3d 1045, 1058-59 (9th Cir.1997) (en banc), vacated on other grounds, 523 U.S. 538, 118 S.Ct. 1489, 140 L.Ed.2d 728 (1998), where a plurality of the Ninth Circuit found the State of California violated a defendant’s right to due process by arguing at his trial that he alone committed a murder, while arguing at a subsequent trial that another defendant committed the same murder. The court held that the prosecutor, by discrediting the evidence he had used in a previous trial that a different defendant was the solitary offender, violated his prosecutorial duty to “vindicate the truth and to administer justice.” Id. at 1058. Ultimately, the court held that “it is well established that when no new significant evidence comes to light, a prosecutor cannot, in order to con[249]*249vict two defendants at separate trials, offer inconsistent theories and facts regarding the same crime.” Id.; see also Smith v. Groose, 205 F.3d 1045, 1052 (8th Cir.2000) (use of witness’s first statement in trial of one defendant and then use of witness’s second, contradictory statement against different defendant in subsequent trial, in order to convict both defendants of same crime, violated due process).
This case differs substantially from these federal cases. Those courts were guarding against multiple defendants being convicted for committing the same crime, which the evidence showed could only have been committed by one perpetrator. Here, the state changed its position about the credibility of a witness. In the federal cases, the government changed its theory and evidence about the perpetrator of the crime. This is a crucial distinction. The Calderon court itself recognized the difference, citing to an opinion by then-judge Kennedy wherein he concluded that “reversal is not required when the underlying theory ‘remains consistent.’ ” 120 F.3d at 1058-59 (quoting Haynes v. Cupp, 827 F.2d 435, 439 (9th Cir.1987)). Post-Calderon, the Ninth Circuit and other courts have explicitly recognized that not every prosecutorial variance amounts to a due process violation. See, e.g., State v. Sanchez, 142 Idaho 309, 322, 127 P.3d 212, 225 (Ct.App.2005) (citing Groose, 205 F.3d at 1052) (“to violate due process, an inconsistency must exist at the core of the prosecutor’s cases against defendants accused of the same crime”). The Ninth Circuit distinguished Calderon in Nguyen v. Lindsey, 232 F.3d 1236, 1240 (9th Cir.2000), where the defendant claimed a due process violation based on the prosecutor’s differing arguments at co-defendants’ trials as to which of them shot first. The court relied on the fact that the prosecutor “presented the same underlying theory of the case at each trial — when a shot kills a third person in a voluntary gun battle, the initiator and those who voluntarily took part in the mutual combat are responsible for the crime.” Id. (emphasis added). Regarding who took the first shot, the court recognized the prosecutor made different arguments at each trial but that “these arguments were consistent with the evidence actually adduced at each trial.” Id. Unlike in Calderon, both defendants could be guilty of the same -crime due to the nature of the crime. Id.; see also State v. Moody, 208 Ariz. 424, 94 P.3d 1119, 1134 (2004) (“[The defendant] is only one person, and the theories offered are not necessarily inconsistent. Thus [Calderon ] is inapposite.”).
In this case, the prosecution was not advancing a different theory or inconsistent evidence in challenging Kenneth’s credibility at Pearce’s trial. To the contrary, the state maintained throughout each trial that Sanchez, Kenneth, John, and Sarah Pearce were all culpable in the attack.
While a prosecutor, as the agent of the people and the state; has the unique duty to ensure a fundamentally fair trial by seeking not only to convict, but also to vindicate the truth and to -administer justice, courts have largely recognized the limits of punishing prosecutors for apparent inconsistencies in their approach to criminal trials absent a “core” inconsistency. See Sanchez, 142 Idaho at 322, 127 P.3d at 225 (citing Groose, 205 F.3d at 1052). We also note there is no evidence the prosecution in this case engaged in premeditated manipulation of evidence. In the previous trials, the State had relied on Kenneth’s testimony that John and Sanchez were the other male assailants — testimony from which Kenneth did not waver throughout the trials. In contrast, during Pearce’s trial, the State was faced with Kenneth’s fluctuating testimony regarding the identity of the female assailant. Forcing the prosecution to simply accept his assertions and abstain from impeachment, simply because it had bolstered his credibility when it previously used a different portion of his testimony, would essentially strip the State of an important tool in its trial arsenal. We conclude Pearce did not suffer a violation of her due process rights, and the district court did not err in denying Pearce’s motion to dismiss.
D.
The district court did not err in denying the motion to admit prior prosecution arguments. •
We next consider whether the district court erred in declining to allow [250]*250Pearce to present the prosecution’s arguments from Sanchez’ first trial and Kenneth’s sentencing hearing to the jury as evidence of the inconsistency.4 Pearce contended these statements should have been allowed in as admissions of a party opponent. The trial court has broad discretion in the admission of evidence at trial and its judgment will be reversed only where there is an abuse of that discretion. State v. Howard, 135 Idaho 727, 731-32, 24 P.3d 44, 48-49 (2001); State v. Zimmerman, 121 Idaho 971, 973-74, 829 P.2d 861, 863-64 (1992).
The question of whether a party may admit a prosecutor’s prior statements in related cases as admissions of a party opponent is one of first impression in Idaho. Courts elsewhere have varied in their treatment of the issue.5 Historically, such statements were rarely admissible. While some courts persist in refusing to admit such statements as party admissions under Federal Rule of Evidence 801(d)(2), see, e.g., United States v. Zizzo, 120 F.3d 1338, 1351 n. 4 (7th Cir.1997), several federal courts have recently endorsed the use of counsel’s inconsistent statements by concluding they are not per se inadmissible. For example, in United States v. McKeon, 738 F.2d 26 (2d Cir.1984), the Second Circuit held that statements of the defendant’s attorney in a criminal ease are admissible in a subsequent trial as an admission of a party opponent where they are: (1) assertions of fact equivalent to a testimonial statement by the client; (2) inconsistent with similar assertions in a subsequent trial; and (3) not subject to an innocent explanation for the inconsistency.6 Id. at 33. In United States v. Salerno, 937 F.2d 797, 811-12 (2d Cir.1991), rev’d on other grounds, 505 U.S. 317, 322, 112 S.Ct. 2503, 120 L.Ed.2d 255 (1992), the Second Circuit specifically applied the McKeon factors to prosecutorial statements. There, the court allowed the admission of certain statements where the prosecutor, in a previous trial, had characterized the defendant contractor as the victim of extortion by a RICO enterprise, but in a subsequent bid-rigging trial had attempted to paint him as culpable in the scam. Salerno, 937 F.2d at 811-12; see also United States v. DeLoach, 34 F.3d 1001, 1005-06 (11th Cir.1994) (citing to McKeon and Salerno, the court upheld exclusion of prosecutor’s statements from earlier trial of co-defendant where prosecutor argued against defendant’s culpability in the first trial and for it in the second after finding the prosecutor’s statements were not statements of fact and were [251]*251not inconsistent with government’s position in its prosecution of the defendant).7
While Pearce relies on the reasoning of these eases, specifically Salerno, to support her contention for admission, a closer examination shows they actually refute it. Both McKeon and Salerno recognized that “serious collateral consequences could result from the unbridled use of such statements.” Salerno, 937 F.2d at 811. In fact, the McKeon court carved out an explicit limitation to admissibility saying that “[sjpeculations of counsel, advocacy as to the credibility of witnesses, arguments as to-weaknesses in the [opponent’s] case or invitations to a jury to draw certain inferences” were excluded from its pronouncement admitting certain prosecuting attorney statements. McKeon, 738 F.2d at 33 (emphasis added). The court implied these were not statements of fact equivalent to testimonial statements by the client, but constituted advocacy regarding witness credibility and inferences to be drawn from the evidence. Id.; accord Salerno, 937 F.2d at 811 (requiring prosecutor’s inconsistent statement to be one of fact if admission is to be appropriate). This limitation recognizes and respects the prosecutorial role in the trial process. As a California appellate court has articulated, “[t]he prosecutor, after all, [is] neither a participant nor a witness, and has no knowledge of the facts other than those gleaned from the witnesses and other available evidence.” People v. Watts, 76 Cal.App.4th 1250, 1263, 91 Cal.Rptr.2d 1 (Cal.Ct.App.1999).
Here, the evidence Pearce sought to admit concerns statements made while the prosecutor was engaged in “advocacy as to the credibility of witnesses,” a circumstance under which McKeon specifically stated an attorney’s comments should not be admissible in a subsequent, related proceeding. McKeon, 738 F.2d at 33; see also DeLoach, 34 F.3d at 1005-06 (upholding lower court’s exclusion of statements made by attorney during closing arguments); People v. Cruz, 162 Ill.2d 314, 205 Ill.Dec. 345, 643 N.E.2d 636, 664-65 (1994) (affirming exclusion of evidence of prosecution’s strategy in earlier, related trial due to competing policy concerns); People v. Morrison, 178 Ill.App.3d 76, 127 Ill.Dec. 248, 532 N.E.2d 1077, 1088 (1988) (refusing admission of prosecutor’s closing argument given in co-defendant’s pri- or trial). Consequently, we conclude the district court did not err when it barred admission of the prosecutor’s previous arguments.
III.
We find that the district court committed no error in the proceedings and therefore affirm Pearce’s judgment of conviction.
Justices BURDICK and HORTON concur.