Is there any case law in which a defense counsel was admonished or reprimanded for misconduct during a closing argument?

California, United States of America

The following excerpt is from Saar v. Niven, G044848, Super. Ct. No. 30-2009-00121669 (Cal. App. 2012):

Plaintiffs assert "many . . . instances of misconduct that occurred during defense counsel's closing argument[] were matters that had originated during witness examination, for which timely objections were made . . . ." They also note each party was "only allowed approximately 30 minutes for closing argument." But they offer no authority for their apparent proposition that either reason justifies the failure to object or request admonitions during the opposing party's closing argument. The claim is forfeited. (Evans v. CenterStone Development Co. (2005) 134 Cal.App.4th 151, 165.)

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