from nolo:

In practice, judges give attorneys great freedom at closing, as long as the argument has some relation to the evidence presented at trial. Additionally, judges must carefully craft any restrictions on closing so that they don’t deny the defendant the opportunity to discuss important considerations for the jury.

Nonetheless, there are limits to proper closing argument. When attorneys overstep them, usually a judge will simply tell the jury to disregard the improper argument. But when attorneys commit serious misconduct during closing, a judge might declare a mistrial, and if not, a court of appeal might overturn any conviction.

Arguments must be based on evidence. Most importantly, the conclusions that an attorney urges a jury to draw must be based on the evidence. Counsel cannot use the closing argument as an opportunity to refer to evidence that wasn’t part of the trial. For example, an attorney can’t argue that no similar crimes have been committed in the location in question since the defendant’s arrest without having presented evidence to that effect.

Arguments cannot be irrelevant, confusing, or prejudicial. Judges can also prohibit or exclude arguments that are unrelated to the case, confusing, or inflammatory. For example, name-calling is generally forbidden. And asking the jury to “send a message” to other criminals by finding the defendant guilty may be improper since the focus is only whether the particular defendant on trial committed a crime. (State v. Woodard, 2013 ME 36 (2013).)

*emphasis mine.
**lots of emphasis on that last emphasis. you know why.