What is the role of counsel in closing argument at a criminal trial?

[43 Cal.3d 390] The federal constitutional right to counsel requires, "at a bare minimum, that defense counsel act as a true advocate for the accused." (People v. Hattery (1985) 109 [729 P.2d 254] Ill.2d 449, 94 Ill.Dec. 514, 488 N.E.2d 513, 517, cert. den. (1986) 478 U.S. 1013, 106 S.Ct. 3314, 92 L.Ed.2d 727.) As the United

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The need for a zealous advocate is particularly important during closing argument. As the United States Supreme Court has emphasized, "There can be no doubt that closing argument for the defense is a basic element of the adversary factfinding process in a criminal trial." (Herring v. New York (1975) 422 U.S. 853, 858, 95 S.Ct. 2550, 2553, 45 L.Ed.2d 593.) "And for the defense, closing argument is the last clear chance to persuade the trier of fact that there may be reasonable doubt of the defendant's guilt." (Id., at p. 862, 95 S.Ct. at p. 2555.)