California, United States of America
The following excerpt is from People v. Sanchez, 2d Crim. No. B259082 (Cal. App. 2016):
Moreover, the trial court may preclude counsel from arguing facts of unrelated, unsubstantiated cases. (People v. Pelayo (1999) 69 Cal.App.4th 115, 122 [trial
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court properly restricted counsel's summation by prohibiting references to newspaper articles concerning children fabricating sex crimes]; People v. Mendoza (1974) 37 Cal.App.3d 717, 725 [trial court properly restricted counsel from reading newspaper articles concerning unrelated crimes].) Thus, a defendant does not have an absolute constitutional right to present closing argument of any kind and scope that he may desire.
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