Is a defendant's right to counsel violated when the trial court severely limits the defense's closing argument?

The defense's closing argument "is a basic element of the adversary factfinding process in a criminal trial" and the complete denial of an opportunity to make a closing argument is a violation of the constitutional right to counsel. (Herring v. New York (1975) 422 U.S. 853, 858-859, 863 (Herring).) In the same vein, a defendant's right to counsel is denied when a trial court seriously limits defense closing argument, as by precluding reference to an entire theory of defense (Conde v. Henry (9th Cir. 1999) 198 F.3d 734, 739) or by not allowing counsel to argue the significance of evidence critical to a theory of the defense (U.S. v. Kellington (9th Cir. 2000) 217 F.3d 1084, 1099-1100).