Simmons v. State

Victor T. Simmons appeals his convictions for delivery of cocaine1 and possession of cocaine,2 contending that the trial court abused its discretion in arbitrarily setting a time limit for defense counsel’s closing argument. We affirm.

Mr. Simmons was accused of selling crack cocaine to an undercover police officer. The transaction was videotaped and another police officer photographed Mr. Simmons immediately following the sale. At trial, the State called three witnesses: the undercover officer who purchased the cocaine, the officer who took the photograph, and the chemist who identified the…