Closing Argument “Summation”

Closing argument is designed to refocus the jury to your story. Revisit the key points of the evidence that supported the issues of the case. Clarify testimony that supports your verdict. Don’t retell the whole case. They are looking for guidance. Give them the tools and the phrasing to argue your case in deliberations. There are two very important tools that will empower the jury to a favorable verdict.

The Jury Instructions and Jury Verdict Form will bring clarity of the evidence and help justify the answers. Jurors often don’t understand what the jury instructions actually mean so they guess. Choose the evidence that supports each verdict question and match it with the law that supports your case. The jury is looking for guidance and appreciates that you make sense of the evidence. Remember, the jury consistently heard conflicting testimony and listened to arguments of what the documents actually meant.

If you use key words of the jury instructions in your opening statement and throughout the trial these words will be familiar in closing argument.

There are legal terms what will be misconstrued and confusing. Simplify these terms. An example would be regarding Causation: Substantial Factor. Most juries believe that substantial fracture means that the evidence must be overwhelming. Misunderstanding of the law has caused many disappointing verdict results.

Note: The Jury will use the law to hang their hats. Show that your facts match up with the law.