Whether a prosecutor's comment on a criminal defendant's failure to testify infringes on the defendant's Fifth Amendment privilege against self-incrimination

QUESTION PRESENTED In considering whether a prosecutor’s comment on acriminal defendant’s failure to testify infringes on the defendant’s Fifth Amendment privilege against selfincrimination, some courts apply a rigid, “necessarily and naturally” test, while others apply more liberal tests. Does the test conflict with this Court’s repeated instruction to construe the Fifth Amendment liberally?