What is the limitation of cross-examination of witnesses in a murder trial?

What occurred here was not an interference with the right to counsel, retained or appointed, but was a restriction on defendant's cross-examination of the witnesses. This was not a situation where defendant's fundamental right to representation was abrogated. Nor was the court required to advise defendant of the pitfalls of his choice such as where a defendant chooses to proceed in propria persona, with joint counsel representing more than one defendant, or with counsel who has a conflict of interest. Although he was not afforded dual cross-examination of witnesses, defendant was otherwise afforded the benefit of two skilled attorneys dedicated solely to his cause throughout his trial, a benefit normally reserved for defendants facing a possible death penalty. "[T]he right [to counsel] is not infringed when 'the opportunity [of the defense] to participate fully and fairly in the adversary factfinding process' [citation] is not significantly limited." (People v. Bonin (1988) 46 Cal.3d 659, 695, 250 Cal.Rptr. 687, 758 P.2d 1217, third set of brackets in original.)

The right of cross-examination as a primary interest secured by the constitutional right to confrontation is not absolute.