California, United States of America
The following excerpt is from People v. Murrietta, H043157 (Cal. App. 2017):
deference to counsel's tactical decisions in his closing presentation is particularly important because of the broad range of legitimate defense strategy at that stage. Closing arguments should 'sharpen and clarify the issues for resolution by the trier of fact,' [citation], but which issues to sharpen and how best to clarify them are questions with many reasonable answers." (Yarborough v. Gentry (2003) 540 U.S. 1, 5-6.) Judicial review of a defense attorney's closing argument is therefore "highly deferential." (Id. at p. 6.)
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