Does a supplemental instruction after closing argument and with no prior notice eviscerate the defense?

The defense immediately objected. Becky now argues that the supplemental instruction, given after closing argument and with no prior notice, eviscerated his defense. As a result, he claims, "counsel's closing argument was based upon a theory of defense which the court rejected, or at least ignored, in its subsequent instructions.... impair[ing] the effectiveness of counsel's argument and hence of appellant's defense." Wright v. United States, 339 F.2d 578, 580 (9th Cir. 1964) (reversing because of the court's instructions' prejudicial effect on counsel's summation).