California, United States of America
The following excerpt is from People v. Milton, B282447 (Cal. App. 2018):
Thus, we conclude the trial court did not abuse its discretion when it limited defense counsel's closing argument. As a result, we need not and do not reach defendant's arguments that the alleged error violated his constitutional rights. " 'No separate constitutional discussion is required, or provided, when rejection of a claim on the merits necessarily leads to rejection of any constitutional theory or "gloss" raised for the first time here.' " (People v. Solomon (2010) 49 Cal.4th 792, 811, fn. 8 (Solomon).)
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