There is no set formula for closing argument. Each case has different strengths and weaknesses. Moreover, juries vary widely in their sophistication and ability to comprehend arguments, and trial judges often have individual practices that shape how closings are presented.
That being said, effective closings are usually built upon a core set of strategies. We described several of them in our May 18 column. There we emphasized the importance of arguing the evidence. We suggested that the beginning of most closing arguments should contain an explanation in simple terms of why your client’s case is just. We also suggested that you should address the burden of proof, regardless of whether you or your adversary must meet it. This column focuses on strategies for retaining jurors’ attention during closing argument and on counsel’s relationship with the jury.
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