In what circumstances will a trial court limit defense counsel's closing argument for abuse of power?

California, United States of America

The following excerpt is from People v. Simon, 1 Cal.5th 98, 204 Cal.Rptr.3d 380, 375 P.3d 1 (Cal. 2016):

We review a trial court's decision to limit defense counsel closing argument for abuse of discretion. (See People v. Rodrigues, supra, 8 Cal.4th at p. 1184, 36 Cal.Rptr.2d 235, 885 P.2d 1.)
On numerous occasions, we have upheld a trial court's refusal to allow defense counsel to compare the defendant to specific well-known murderers or their crimes. (See, e.g., People v. Virgil (2011) 51 Cal.4th 1210, 12851287, 126 Cal.Rptr.3d 465, 253 P.3d 553 ;

[375 P.3d 36]

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