What is the test for limiting the scope of a trial judge's closing argument?

California, United States of America

The following excerpt is from People v. Roberts, B279633 (Cal. App. 2017):

The trial court as well has "great latitude in . . . limiting the scope of closing summations. . . . [It] may ensure that argument does not stray unduly from the mark, or otherwise impede the fair and orderly conduct of the trial. In all these respects [the trial judge] must have broad discretion." (Herring v. New York (1975) 422 U.S. 853, 862 (Herring).) The trial judge's limitations on closing argument are reviewed under the abuse of discretion standard. (People v. Edwards (2013) 57 Cal.4th 658, 743.)

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