The following excerpt is from U.S. v. Magana-Olvera, 917 F.2d 29 (9th Cir. 1990):
Generally speaking, we review a trial court's control of closing arguments for an abuse of discretion. However, because the issue here implicates a constitutional right, our review is de novo. See United States v. Schuler, 813 F.2d 978, 980 (9th Cir.1987).
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