Judge GIERKE
delivered the opinion of the Court.
A general court-martial composed of officer and enlisted members convicted appellant, contrary to his pleas, of 37 specifications of larceny, 25 specifications of forgery, and one specification each of wrongfully using and of making an Armed Forces Identification Card, in violation of Articles 121, 123, and 134, Uniform Code of Military Justice, 10 USC §§ 921, 923, and 934, respectively. The adjudged sentence provides for a dishonorable discharge, confinement for 15 years, total forfeitures, a fine of $15,000 (enforced by an additional 5 years of confinement if the fine is not paid), and reduction to the lowest enlisted grade. The convening authority approved the sentence with a slight modification of forfeitures. The Court of Criminal Appeals affirmed the findings and sentence. 50 MJ 577 (1999).
Our Court granted review of two issues:
I
WHETHER THE LOWER COURT ERRED IN FINDING NO PREJUDICE WHERE THE TRIAL COUNSEL COMMITTED PLAIN ERROR BY REPEATEDLY ASKING APPELLANT ON CROSS-EXAMINATION WHETHER NUMEROUS WITNESSES WHO HAD TESTIFIED INCONSISTENTLY WITH APPELLANT WERE LYING.
II
WHETHER TRIAL COUNSEL COMMITTED PLAIN ERROR BY ARGUING FOR INCREASED PUNISHMENT BECAUSE APPELLANT PURPORTEDLY TESTIFIED FALSELY.
For the reasons set out below, we affirm.3
ISSUE I: TRIAL COUNSEL’S CROSS-EXAMINATION
Facts
Appellant was the supply sergeant at Separations Company, Camp Pendleton, California. Marines who were being discharged were out-processed by Separations Company. They would receive a final accounting of pay, after which Separations Company personnel would mail a final pay check to the discharged Marine. The theory of the prosecution was that appellant stole those final pay checks before they were mailed, then either cashed them or procured others to cash them, using fraudulent Armed Forces Identification Cards.
Chief Warrant Officer (CWO) Gorman, executive officer of Separations Company, testified that one of appellant’s duties was to compile the “shopping list” of supplies requested by members of the company. The prosecution presented documentary evidence showing that appellant ordered and received a package of 100 blank Armed Forces Identification Cards, but the identification cards were never received by Separations Company. The supply documents appear to bear the signatures of CWO Gorman, as the officer requesting the identification cards, and Staff Sergeant (SSgt) Garza, chief of administration, acknowledging receipt of the cards. Both CWO Gorman and SSgt Garza testified that they did not sign the documents.
Naval Criminal Investigative Service (NCIS) Special Agent (SA) McKenzie testified that appellant was questioned about the missing identification cards and consented to a search of his off-base residence. During the search, NCIS agents found a blank identification card inside a record album. Inside a large vase the agents found a manila envelope containing three partial identification cards bearing the names of three of the [14]*14alleged victims and small pieces of other identifications cards. The envelope also contained a cut up identification-card photo of Sergeant (Sgt) Spencer, one of appellant’s alleged co-actors, and a partial identification-card photo of appellant. The back of the envelope contained “practice signatures.” The NCIS agents also found lamination material in a dining room closet and an identification-card-sized photograph of appellant in a wall unit in the living room.
The NCIS agents also searched appellant’s personal vehicle. In a storage pouch at the rear of the driver’s seat they found a copy of the document requesting issuance of the blank identification cards, purporting to bear CWO Gorman’s and SSgt Garza’s signatures.
Corporal (Cpl) Saenz-Ortega testified about the procedures used by Separations Company to issue and mail pay checks. He described one occasion when a check was discovered missing and was later recovered by appellant from a trash can in front of another building and turned in to CWO Gorman.
All three of appellant’s co-actors testified against him pursuant to grants of immunity. Patricia Gibson, a civilian payroll technician, testified that she and appellant became friends and that the friendship evolved into an “intimate relationship.” She testified that, at appellant’s request, she endorsed the backs of a number of Treasury checks made out to various individuals and signed several identification cards.
Former-sergeant Jessie James Spencer testified that when discharged Marines started calling Separation Company about missing checks, he suspected that appellant was stealing them. His suspicions arose because appellant seemed to have a lot of money and because he observed what appeared to be a surreptitious conversation between appellant and Cpl Kevin Lynk. He told appellant that he “wanted in.” Spencer described how he and appellant stole the checks from the outgoing mail, made phony identification cards reflecting the names of the payees on the stolen checks, and cashed the checks.
Former-corporal Kevin Lynk testified that he worked for appellant for a year. He testified that appellant asked him to cash a check that had been returned to the company. He agreed after appellant “persistently asked [him] for about two weeks.” Appellant used the Polaroid camera from the company to take Lynk’s photograph and then made him a phony identification card. Lynk used the phony identification card to cash the check and shared the proceeds with appellant. Lynk subsequently cashed two more checks for appellant and shared the proceeds with him.
There was no dispute that the checks had been stolen and forged. Nevertheless, the prosecution presented expert testimony and documentary evidence establishing that the named payees did not endorse the checks, and the defense so stipulated. In addition, the prosecution presented evidence that appellant’s fingerprints were identified on a small piece of paper in the vase containing the pieces of identification cards and cut-up photographs, and on 12 of the forged checks. Spencer’s fingerprints were identified on seven forged checks.
The defense theory, articulated in civilian defense counsel’s opening statement, was that Spencer and Lynk were involved in a conspiracy to cash government checks, that they “became the object of suspicion,” and that they decided to frame appellant to “get the heat or the trail off of them.” With respect to Ms. Gibson, the defense theory was that she was “the spurned woman” who was jealous because appellant became involved with another woman.
Appellant testified in his own defense. He testified that the vase containing the evidence seized by the NCIS agents was in his office until April of 1996, when he moved it and a number of other personal items from his office to his residence. He testified that Ms. Gibson helped him by transporting the items, including the vase, in her car while he rode his motorcycle to his home.
He testified that he was in the bathroom when NCIS agents removed the brown envelope from the vase. He stated that he did not know how the envelope was placed in the [15]*15vase. He speculated that it must have happened at work.
Appellant explained his fingerprints on the forged checks by testifying that he handled cheeks by assisting Sgt Spencer sort the incoming mail. The checks were in “return to sender” mail, which appellant and Sgt Spender opened and sorted.
Appellant denied taking checks or mail from the outgoing mail box. He denied cashing any of the checks. He denied sharing in the proceeds of any of the checks. He denied having any “clandestine meetings” with Lynk.
Appellant admitted obtaining the blank identification cards. He testified that CWO Gorman told him to take the “shopping list” to supply and that the list was already prepared.
Regarding the missing-check incident described by Cpl Saenz-Ortega, appellant testified that all the Marines in the company were assembled because of the missing check. After they were released, appellant “took it upon [himself] to check the trash cans” around “an abandoned building.” He testified that he saw the check in the trash can, brought the entire trash can back to the company, and watched while CWO Gorman, in the presence of the first sergeant and the Military Police, retrieved the check from the trash can.
Appellant testified that when he returned from supply with the blank identification cards, he gave them and the paperwork to Cpl Lynk and instructed him to take the identification cards to the administration area and to bring back the receipt. Cpl Saenz-Ortega placed the receipt in appellant’s mail box in the administration section. Appellant denied signing SSgt Garza’s name on the receipt for the blank identification cards.
The questions forming the basis of the first granted issue occurred during cross-examination of appellant. Trial counsel asked four times if CWO Gorman was lying when he said that it was appellant’s job to type the “shopping list.” Appellant responded that CWO Gorman did not know who typed the list. He testified that some of CWO Gorman’s testimony was incorrect, because CWO Gorman changed the procedures. Tidal counsel asked once if CWO Gorman was lying when he testified that picking up blank identification cards was one of appellant’s “main duties.” Appellant responded that CWO Gorman was not lying.
Trial counsel asked if Cpl Saenz-Ortega was lying when he testified that “there was no trash can involved” in the recovery of the missing check. Appellant responded without characterizing the truthfulness of SaenzOrtega’s testimony; he testified, “Ma’am, there was a trash can involved in the situation.”
Trial counsel asked three times if government witnesses were lying when they testified that appellant was not authorized to touch the Treasury checks. Appellant responded that he did not know if they were lying because he did not know if he was authorized to handle the checks.
Trial counsel asked five times if Cpl Lynk was lying when he testified that appellant gave him checks and “hounded him” to cash them. Appellant responded that Lynk was lying. Trial counsel asked if Lynk was lying when he testified that he had never seen the record album where the blank identification card was found, and appellant again responded that Lynk was lying.
Trial counsel asked if Ms. Gibson “made those events up,” meaning her involvement in the endorsement of checks and preparation of a phony identification card, and appellant responded, “Yes, ma’am.” Trial counsel asked if Ms. Gibson was lying when she testified that appellant gave the “other woman” $5000 to purchase a car, and appellant responded, “Yes, ma’am.”
Trial counsel asked five times if former-sergeant Spencer was lying. Appellant responded in the affirmative.
Finally, trial counsel asked six times if SA McKenzie was lying about finding the envelope in the vase in appellant’s presence. Appellant responded in the affirmative.
Defense counsel did not object to any of the questions about lying, except on one oc[16]*16casion when he objected on the ground that the question was “vague as to ‘lying’ ” and the judge sustained the objection.
Closing arguments focused on credibility of the witnesses and appellant. Trial counsel’s argument included the following:
Gentlemen, as the factfinders, it’s going to be your duty to judge the credibility of the witnesses.
Consider what they said in the courtroom today and over the last three days. Consider the demeanor of all of those that you’ve seen in the courtroom. When you consider that, you consider who was the slickest witness you saw was [sic]. You consider who had the ready answer to every question.
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The evidence is before you. The evidence is black and white. If all these people came in here and lied, the thief s a liar too. There is only one conclusion, gentlemen. The thief and a liar is guilty of each and every one of those offenses before you on that charge sheet.
Defense counsel’s closing argument included the following:
I think Patricia Gibson has some feelings for my client. And in these domestic type of situations, hell hath no fury like a woman — a spurned woman.
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My client’s the only one who said, “I didn’t do it. These guys did it, and they’re framing me.”
The Court of Criminal Appeals held that trial counsel’s cross-examination constituted “clear and obvious error,” but “these questions nonetheless did not materially prejudice the substantial rights of appellant.” (Emphasis in original.) The court found the Government’s evidence overwhelming and concluded that “the errors were harmless under the particular facts of this case.” 50 MJ at 580.
Appellant now asserts that the court below erred by finding that the errors were harmless. He argues that his “entire defense rested upon his own credibility” and that trial counsel’s improper cross-examination “struck at the very heart of this defense and undermined Appellant’s entire case.” Final Brief at 4.
The Government asserts that trial counsel’s cross-examination was not error at all, much less plain error. Answer to Final Brief at 2.
Amicus curiae assert that trial counsel’s questions were improper because they infringed on the court members’ role in determining the credibility of witnesses, that the Government’s ease was not overwhelming, and “that the error materially prejudiced” appellant’s “right to a fair trial.” Amicus Brief at 1.
Discussion
Mil.R.Evid. 608(a), Manual for Courts-Martial, United States (1995 ed.),4 permits the credibility of a witness to be attacked or supported by evidence in the form of an opinion, but the evidence may refer only to the witness’ character for truthfulness or untruthfulness. This Court has consistently held that a witness may not opine that another witness is lying or telling the truth. See, e.g., United States v. Birdsall, 47 MJ 404, 410 (1998); United States v. Marrie, 43 MJ 35, 41 (1995). The basis for this rule was set out in United States v. Cameron, 21 MJ 59, 63 (1985), where this Court reiterated:
The rule remains that, absent unusual circumstances, opinion testimony on whether or not to believe a particular witness’ testimony simply is not deemed helpful to the factfinder, for the factfinders are perfectly capable of observing and assessing a witness’ credibility.
This Court has not directly addressed the question whether it is improper for trial counsel to ask an accused to opine whether the government witnesses against him ai'e lying. The Second Circuit addressed the [17]*17issue, however, in United States v. Richter, 826 F.2d 206, 208 (1987). That court held that “[p]rosecutorial cross-examination which compels a defendant to state that law enforcement officers lied in their testimony is improper.” In Richter, the prosecutor not only asked the defendant if the FBI agent was lying, he also called another FBI agent to corroborate the first agent’s testimony, “which the prosecutor already had forced the defendant to label” as a lie. The prosecutor then compounded the error in his final argument, focusing on the differences between the testimony of Richter and the FBI agents and arguing that “if [the jurors] find that the FBI agents are telling the truth, then Mr. Richter is guilty and his guilt has been established.” The prosecutor concluded by rhetorically asking the jury why two experienced FBI agents would “commit perjury and risk their careers to get Mr. James Richter.” 826 F.2d at 208-09. The court found “plain and prejudicial error” and reversed. 826 F.2d at 207.
In subsequent cases, the Second Circuit has adhered to the basic principle that it is improper for a prosecutor to compel a defendant to state that the law enforcement officers testifying against him or her are lying. The court has made clear, however, that each case must be analyzed to determine if the improper cross-examination was prejudicial. See United States v. Gaind, 31 F.3d 73, 77 (1994); United States v. Weiss, 930 F.2d 185, 195, cert. denied, 502 U.S. 842, 112 S.Ct. 133, 116 L.Ed.2d 100 (1991); United States v. Scanio, 900 F.2d 485, 492-93 (1990), overruled on other grounds, Ratzlaf v. United States, 510 U.S. 135, 136 n. 1, 114 S.Ct. 655, 126 L.Ed.2d 615 (1994); see generally United States v. Williamson, 53 F.3d 1500, 1522-23 (10th Cir.1995) (analyzing Second Circuit’s application of Richter).
Three other circuits have expressly adopted the Richter principle. See United States v. Sanchez, 176 F.3d 1214, 1219 (9th Cir.1999); United States v. Sullivan, 85 F.3d 743, 749-50 (1st Cir.1996); United States v. Boyd, 54 F.3d 868, 871 (D.C.Cir.1995). In Williamson, supra at 1523, the Tenth Circuit declined to decide whether to adopt the Richter principle, but remarked that it was “not particularly persuaded by the reasoning of the court in Richter.” In United States v. Bryant, 770 F.2d 1283, 1291 (5th Cir.1985), cert. denied, 475 U.S. 1030, 106 S.Ct. 1235, 89 L.Ed.2d 343 (1986), the Court of Appeals held:
We cannot say that Bryant is prejudiced when he is given an opportunity to affirm that contradictory testimony is fallacious. The error, if any, is harmless.
United States v. Cole, 41 F.3d 303, 309 (7th Cir.1994), cert. denied, 516 U.S. 826, 116 S.Ct. 94, 133 L.Ed.2d 49 (1995), appears to have carved out an exception to the Richter principle. The court acknowledged that credibility of witnesses is the province of the jury, but held that it was not improper to ask the defendant if the witnesses against him had any motive to lie after he opened the door on direct examination by repeatedly raising “questions of the character and credibility of government witnesses.”
In our view, the Richter principle, applied on a case-by-case basis, represents the weight of authority and is consistent with our jurisprudence. Applying that principle, we conclude that there was no plain error.
With respect to trial counsel’s questions whether appellant’s three co-actors (Spencer, Lynk, and Gibson) were lying, we conclude that appellant was not prejudiced. Defense counsel announced in his opening statement that appellant was framed by Spencer and Lynk. He asserted that Gibson was a “spumed woman,” implying that she was bent on revenge. Defense counsel adhered to this theme in closing arguments. For trial counsel to force appellant to acknowledge under oath what his counsel had already asserted was harmless error. See United States v. Cole, supra.
With respect to the questions whether CWO Gorman was lying, appellant did not take the bait. He refused to call CWO Gorman a liar, insisting instead that CWO Gorman did not know who typed the shopping lists and that CWO Gorman changed the procedures. While the questions were improper, the answers were harmless.
[18]*18Similarly, with respect to questions regarding appellant’s fingerprints on the checks, appellant declined to call the witnesses against him liars, testifying that he did not know if he was authorized to handle the checks. Regarding the question whether appellant brought the entire trash can containing a missing check to the company offices, he declined to call Cpl Saenz-Ortega a liar. Instead, he simply insisted, “Ma’am, there was a trash can involved in the situation.”
Finally, even though appellant was induced to testify repeatedly that SA McKenzie was lying, we hold that the error was harmless. Appellant did not dispute that the agents found the envelope somewhere, and, consistent with his theory that he was framed, he speculated that it must have been placed in the vase at work. He also suggested that Ms. Gibson had the opportunity to plant the envelope in the vase when she transported his personal effects from his office to his residence.
In summary, the record shows that appellant was confronted with the testimony of his three co-actors, corroborated by the physical evidence seized from his residence, documentary evidence in his car, and his fingerprints on 12 of the forged checks. His defense was that his co-actors were lying in an effort to frame him. Trial counsel’s questions, although improper, merely reinforced the defense theory. Under these circumstances, we hold that the court below did not err when it concluded that appellant was not prejudiced by trial counsel’s improper cross-examination.
ISSUE II: TRIAL COUNSEL’S SENTENCING ARGUMENT
Trial counsel’s sentencing argument included the following comments:
Trust and honor. You heard those words from several people who came in this courtroom. Not from the accused. Trust and honor are what Marines stand proud on. Trust and honor.
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The Marine Corps trusted a sergeant. Trusted a sergeant with numerous responsibilities. What did he do? He took advantage of Separations Company. He took advantage of each and every Marine in that company when he fooled them, and then he came up here and he lied about their involvement.
He lied about Corporal Saenz^Ortega and Corporal Thomas....
Think about those Marines and how they feel being investigated. They’re responsible for those checks. Consider that. Consider those junior Marines. He’s a thief and a liar who’s taken advantage of them.
He’s a thief, a liar, and the ringleader who was involving other Marines in his acts. And he was stealing from Marines who had served honorably.
You, as members, are going to determine his fate. He’s a thief and a liar----
* * *
Consider: “Ye shall not steal, neither deal falsely, neither lie one to another.” Leviticus, Chapter 9, Verse 11____
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The Marine Corps does, in fact, stand for honor. It stands for trust. It stands for everything that we in the Marine Corps are proud of.
Dishonorable Discharge is the only way this Marine should get out of the Marine Corps.
He lied to you, gentlemen. He lied on that stand, and he lied to you. Each and every one of you, he lied to you. Dishonor. Dishonorable discharge.
He has no rehabilitative potential. No way. And he’s got to be punished. [19]*19Punish him with confinement. Twenty-five victims, 25 checks, 25 years. Twenty-five years, and you send that message to each and every Marine at Camp Pendleton. Twenty-five years, and it’s going to hit him that he’s actually done something wrong.
❖ i'.i *
Fine him. Fine him. Fine this thief, and fine this liar. Fine him $50,000.
Twenty-five years confinement; a dishonorable discharge; and $50,000 fine for everything that he’s done to malign the United States Marine Corps, for the horrible example that he has set, what society have seen. And send that message to those sergeants in the Marine Corps, to everyone in the Marine Corps, that what it means to be a Marine is something sacred and important.
Thank you, gentlemen.
Defense counsel did not object to any of the above comments or request a curative instruction. Defense counsel did object, however, to trial counsel’s asking the members to think about the impact on other Marines who were investigated as a result of appellant’s misconduct. The military judge sustained this objection and gave a curative instruction.
The military judge’s instructions on sentencing included the following limiting instructions:
No person, including the accused, has the right to seek to alter or affect the outcome of a court-martial by false testimony. You’re instructed that you may consider this issue only within certain constraints. First, this factor should play no role whatsoever in your determination of an appropriate sentence unless you conclude that the accused did lie under oath to the court. Second, such lies must have been in your view willful and material before they can be considered in your deliberations.
Finally, you may consider this factor insofar as you conclude that it, along with all other circumstances in the ease, bears upon the likelihood that the accused can be rehabilitated.
You may not mete out additional punishment for the false testimony itself.
During argument, trial counsel and defense counsel recommended that you consider a specific sentence or parts of the sentence in this case. You’re advised that the arguments of counsel and their recommendations are only their individual suggestions and may not be considered as the recommendation or opinion of anyone other than such counsel.
Appellant and amicus curiae now argue that trial counsel’s sentencing argument was plain error, because she improperly asked the members to punish appellant for lying. Final Brief at 10-11; Amicus Brief at 13. At one point in its brief, the Government concedes that the argument was improper, but argues that it does not rise to the level of “plain error because appellant suffered no prejudice.” Answer at 3. At another point, however, the Government asserts that “trial counsel’s argument was not error.” Answer at 10.
It is well established that “a trial counsel ‘may strike hard blows, [but] he [or she] is not at liberty to strike foul ones.’ ” United States v. Stargell, 49 MJ 92, 93 (1998), quoting Berger v. United States, 295 U.S. 78, 88, 55 S.Ct. 629, 79 L.Ed. 1314 (1935). RCM 1001(g), Manual, supra, provides: “Failure to object to improper argument before the military judge begins to instruct the members on sentencing shall constitute waiver of the objection.” To overcome waiver, appellant must convince this Court that the argument was error, that the error was plain or obvious, and that the error materially prejudiced his substantial rights. United States v. Powell, 49 MJ 460, 464-65 (1998).
In United States v. Warren, 13 MJ 278 (1982), this Court held that an appellant’s mendacity may be considered in sentencing, subject to certain limitations. When sentencing is by members, the military judge must instruct the members that they may not consider trial counsel’s mendacity argument “unless they conclude that the accused did lie under oath to the court” and that [20]*20“such lies must have been, in [the members’] mind, ‘willful and material.’ ” Finally, the members may consider an accused’s mendacity “only insofar as they conclude that it, along with all the other circumstances in the case, bears upon the likelihood that the accused can be rehabilitated.” The court members “may not mete out additional punishment for the false testimony itself.” 13 MJ at 285-86 (all emphasis in original).
Court members are presumed to follow the military judge’s instructions. See United States v. Garrett, 24 MJ 413, 418 (CMA 1987), citing United States v. Ricketts, 1 MJ 78, 82 (CMA 1975). This Court has recognized that an improper argument can often be cured by an appropriate limiting instruction. See, e.g., Stargell, 49 MJ at 94; United States v. Vasquez, 48 MJ 426, 430 (1998).
Applying the foregoing principles to trial counsel’s argument in this case, we hold that thei'e was no plain error. Although trial counsel repeated called appellant a thief and a liar, defense counsel did not find the argument sufficiently offensive to warrant an objection or a request for a curative instruction. The military judge’s detailed and appropriate limiting instruction cured any possible error in trial counsel’s sentencing argument.
Decision
The decision of the United States Navy-Marine Corps Court of Criminal Appeals is affirmed.