The following excerpt is from Bonin v. Calderon, 59 F.3d 815 (9th Cir. 1995):
It is clear that a criminal defendant has a constitutional right to effective representation, including a right to make a closing argument. Herring v. New York, 422 U.S. 853, 858, 95 S.Ct. 2550, 2553, 45 L.Ed.2d 593 (1975). But there is certainly no federal constitutional right to have two attorneys make closing arguments even in death penalty cases. See id. at 862, 95 S.Ct. at 2555 (trial court has great latitude to regulate argument).
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