California, United States of America
The following excerpt is from People v. Harris, A149770 (Cal. App. 2018):
The Sixth Amendment right to counsel includes the "right to have counsel present closing argument to the trier of fact." (People v. Marshall (1996) 13 Cal.4th 799, 854; see also Herring, supra, 422 U.S. at p. 862 ["[F]or the defense, closing argument is the last clear chance to persuade the trier of fact that there may be reasonable doubt of the defendant's guilt"].)
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