Commonwealth v. Haas, 373 Mass. 545 (1977)
“’Great latitude should be permitted to counsel in argument.’ Commonwealth v. Pettie, 363 Mass. 836, 840 (1973). Nevertheless, final arguments cannot be freewheeling, extemporaneous, verbal slugfests. Lawyers shall not and must not misstate principles of law nor may their summations infringe or denigrate constitutional rights. Advanced preparation would eliminate from our consideration most aspects of closing arguments constantly being urged as improper. We remind counsel that we shall not tolerate misconduct by lawyers during the persuasion phase of a criminal trial.”
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