What is the scope of closing arguments in criminal cases?

Moreover, as the high court cautioned, the Herring rationale was not intended to prevent trial courts from controlling the scope of closing arguments: "This is not to say that closing arguments in a criminal case must be uncontrolled or even unrestrained. The presiding judge must be and is given great latitude in controlling the duration and limiting the scope of closing summations. He may limit counsel to a reasonable time and may terminate argument when continuation would be repetitive or redundant. He may ensure that argument does not stray unduly from the mark, or otherwise impede the fair and orderly conduct of the trial. In all these respects he must have broad discretion." (Herring, supra, 422 U.S. at p. 862; see also People v. Marshall (1996) 13 Cal.4th 799, 854 -855 ["A criminal defendant has a well-established constitutional right to have counsel present closing argument to the trier of fact. [Citations.] This right is not unbounded, however; the trial court retains discretion to impose reasonable time limits and to ensure that argument does not stray unduly from the mark."].)