What rights does counsel have to make a closing argument in a criminal case?

"The right to counsel guaranteed by the Sixth Amendment to the federal Constitution includes the right of counsel to make a closing argument in a criminal case. [Citation.]" (People v. Diggs (1986) 177 Cal.App.3d 958, 969, fn. omitted.) "Closing argument may be waived in an appropriate case as a matter of tactics. [Citations.] However, having chosen to make a closing argument, counsel cannot argue against his client. [Citations.] More particularly, unless his client consents, counsel cannot expressly or impliedly argue to the jury that his client is guilty. [Citations.]" (Id. at p. 970.)

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