What is the scope of the closing arguments of a criminal trial?

In addition to being an open question, it is a difficult and nuanced one. Closing arguments of defense counsel have long been recognized as a fundamental aspect of a fair trial, and a judge presiding over trial "must be and is given great latitude" over the scope of summations. Herring v. New York , 422 U.S. 853, 862, 95 S.Ct. 2550, 45 L.Ed.2d 593 (1975). Appellate courts are not well-suited, particularly on truncated records involving ongoing proceedings, to ensure that a trial is fair.