In People v. Radovich (1932) 125 Cal.App. 77, the defense attorney during argument attempted to read from a volume of the California reports. The court instructed counsel not to do so and stated, "the court will attend to all of the law in this case." Defense counsel persisted and expressed a desire to refer to certain other cases. The court at that point described the conduct of counsel as being contemptuous and forbade counsel to address the jury on any subject other than the facts. Although the judgment was affirmed, this statement by the trial judge was criticized by Mr. Witkin in California Criminal Procedure, Trial, section 467, at pages 474-475, thusly: "But this is unsound: Counsel can go beyond the facts . . ., and must be entitled to make any reference to the law necessary for an understanding of the argument on the facts."