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Making Closing Argument more Effective by Using Charts and Graphics

One of my passions as a lawyer is to become the best communicator I can be. I am interested in learning new communication methods, to become better at giving closing arguments. I offer these comments to share my knowledge on the issue.

In Closing argument, I want the jury to learn something about me or try to find different ways to regain the attention of the jury.  One way to do this is with charts or personal stories.

I try to create an analogy about my family, often my daughter to tell a lesson in the case. In DUI cases, often the officer has a perception that everything is a sign of DUI. Cannot find your license, because you are under the influence, not because you are nervous or found it in 5 seconds instead of 2 as the officer thought you should. Cannot balance on one leg, it is the alcohol, not that you just do not have great balance. Sometimes perception is an issue. This is an opportunity to make this point with a story.

I have two dogs, when I open the door to let them in the retriever flies in the house, the Terrier, I have to yell for; One day my daughter is yelling at the Terrier and I look at my wife and we say, guess we should not yell for him so much.

Just as my daughter’s perception is shaped by our actions, the officer’s perception is shaped by what he expects to see, always looking for signs of drunk driving. With young children, they are always noticing things you do not see, or seeing things in a different way and this is point that most jurors would recognize.


In addition to stories, one of the things I like to try to do in all cases is to use some kind of chart or exhibit. People learn in different ways; try to present the image as a teacher, allow the jury to see a chart to simplify things.

One area that I use a chart on is the field sobriety tests. I list the clues on the nine step walk and turn so that the jury can see how many things that the officer is looking for.

In the George Zimmerman trial, Attorney Mark Mara used several different charts and diagrams. He used a chart demonstrating the burden of proof on reasonable doubt and one showing what the Government needed to show to find that Zimmerman did not act in self-defense.

In the OJ Simpson trial, in Attorney Barry Scheck present a chart where he showed that all of the evidence flowed to the Los Angles police department which he labeled a black hole before passing to the FBI and California Department of Justice for testing. This chart fit there theory that the police department could not be trusted given the evidence of racism from a lead detective in the case.  To see the portion of the closing just discussed you may click on this link to Scheck’s Closing Argument.

In the case Anthony Trial, Attorney Jose Baez put a board up who smelled what, put pictures of 8 witnesses from different background that did not smell anything. The Board with each witness picture was a great way to spend time teaching the jury the importance of the point he was making; it was done in a memorable easy to understand way. One of the key teachings of Posner and Dodd on Cross Examination is time is the measure of importance in the Court; we want to spend more time on our good facts so that the jury discussing them during deliberation.

There are many examples in Trials of use of trial graphics and exhibits. If you are a lawyer and want to discuss ideas for your next Trial, I would be happy to share any input I have with you.  I can be reached through my website DelSignoreDefense.com and on my office FaceBook Page.

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