Is a trial judge permitted to interrupt a summation when counsel misrepresents the facts?

It is within the trial court's discretion to interrupt a summation when counsel misrepresents the factual record. See United States v. Mieles, 481 F.2d 960, 963 (2d Cir. 1973). Still, we must decide "whether the summation[]... w[as] so hindered by the trial court's interruptions as to have abridged [Kalish's] constitutional rights." United States v.

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Busic, 592 F.2d 13, 36 (2d Cir. 1978). Even where "the trial judge's conduct left something to be desired," Untied States v. Amiel, 95 F.3d 135, 146 (2d Cir. 1996), we will reverse a conviction only if "the jurors have been so impressed by the judge's partiality that it affected their deliberations," United States v. Tocco, 135 F.3d 116, 129 (2d Cir. 1998); see also Busic, 592 F.2d at 37.