📄 Jury instruction: evidence and privilege — Tuesday, December 3, 1996
Address:
C:\DEPT103\CIVIL\1996\DEC\3\JURY-INSTRUCTION-EVIDENCE-AND-.DOC
TRIAL
▲ Day 24 of 57

Jury instruction: evidence and privilege

Date: Tuesday, December 3, 1996 • Utterances: 7
Judge Fujisaki gave the jury a detailed limiting instruction after plaintiffs' counsel Daniel Petrocelli questioned O.J. Simpson about a lie detector test during his examination. The judge explained that attorney-client communications are privileged, that Petrocelli's questions (including references to a 'minus 22' score indicating 'extreme deception') are not evidence, and that the jury must treat the entire subject as if they had never heard it. The instruction was necessitated because defense counsel Bob Baker had opened the door to the lie detector topic in his opening statement.
1 THE COURT:

Morning, ladies and gentlemen.

2 JUROR:

Morning, Your Honor.

3 THE COURT:

Ladies and gentlemen, the Court at this time will give you specific instructions regarding the plaintiffs' examination of Mr. Simpson which was just completed concerning lie detectors.

I want you to listen very closely.

All communications between an attorney and his client are absolutely privileged.

This means that such communications cannot be used by anyone for any purpose except with the permission of the client.

Mr. Simpson cannot be asked any questions about any communications with his attorneys. Furthermore, there is no evidence that Mr. Simpson consented to the publication of any of his communications with his attorney.

You will recall, Mr. Simpson's attorney, Mr. Baker, in his opening statement to you, spoke on the subject of a lie-detector test. By this opening statement, Mr. Simpson opened the subject of lie detectors to examination by the plaintiff. This, however, did not open the subject of any communication on this matter between Mr. Simpson and his attorneys, or persons acting for the attorneys for any purpose.

In this trial, Mr. Petrocelli questioned Mr. Simpson whether he took a lie-detector test, any score and meaning thereof. I instruct you that his questions do not and cannot establish that Mr. Simpson took a die lie-detector test, a score and meaning thereof. Statements of counsel, that is, the statements or questions of Mr. Petrocelli, are not evidence and may not be considered by you for any purpose. The references or statements regarding a lie-detector test and Mr. Petrocelli's questions are not evidence unless they were adopted by Mr. Simpson in his answers. A question by itself is not evidence. You may consider questions only to the extent the content of the questions are adopted by the answer. Mr. Simpson's answer to the question of whether he took a lie-detector test was that he was given an explanation of how the test worked and that he did not take the test.

There is no other evidence before you that Mr. Simpson took a lie-detector test, and the plaintiff is bound by Mr. Simpson's response.

Likewise, when Mr. Petrocelli asked Mr. Simpson whether he knew what the score on the test was, whether it was a minus 22, or whether it indicated extreme deception, these were questions by an attorney and do not constitute evidence. Mr. Simpson denied any test score or any knowledge of what test scores meant, and there is no evidence before you of any test score or what a score means. There was only Mr. Petrocelli's questions which were not adopted by an answer. Plaintiff is bound by Mr. Simpson's response.

Therefore, there is no evidence before you that Mr. Simpson took a lie-detector test, no evidence about any score on such a test, nor any evidence of what any score means. You must totally disregard the questions about taking lie-detector tests, test scores and their meanings, and treat the subject as though you had never heard of it.

Do all of the jurors understand these instructions?

4 JURORS:

Yes.

5 THE COURT:

Do any of the jurors have any questions about these instructions?

6 (Nod negatively.)
7 THE COURT:

Okay. Thank you.

Plaintiffs may call their next witness.

Temperature

procedural

Key Quotes (4)

Hiroshi Fujisaki
All communications between an attorney and his client are absolutely privileged. This means that such communications cannot be used by anyone for any purpose except with the permission of the client.
Establishes the legal basis for why Petrocelli's line of questioning overstepped — the privilege wall protects any attorney-client discussion of the lie detector test.
Hiroshi Fujisaki
when Mr. Petrocelli asked Mr. Simpson whether he knew what the score on the test was, whether it was a minus 22, or whether it indicated extreme deception, these were questions by an attorney and do not constitute evidence.
Reveals the explosive content Petrocelli injected before the jury — a specific score of minus 22 and the phrase 'extreme deception' — which the judge then had to instruct the jury to forget entirely.
Hiroshi Fujisaki
You must totally disregard the questions about taking lie-detector tests, test scores and their meanings, and treat the subject as though you had never heard of it.
The classic 'unring the bell' instruction — the jury has already heard the damaging framing and is now told to pretend they haven't.
Hiroshi Fujisaki
Mr. Simpson's answer to the question of whether he took a lie-detector test was that he was given an explanation of how the test worked and that he did not take the test.
Locks in Simpson's sworn answer as the only evidence of record — he claimed he did not take the test — binding the plaintiff to that response.

Evidence (1)

Informal
Lie detector test allegedly administered to O.J. Simpson, including a purported score of minus 22 said to indicate 'extreme deception'
discussed and then struck from the record by judicial instruction — jury told to disregard entirely

Notable Exchanges (1)

Hiroshi FujisakiJurors
After a lengthy remedial instruction, Fujisaki asked if all jurors understood and if any had questions. Jurors confirmed understanding verbally and then shook their heads negatively to indicate no questions.
procedural

Witness Demeanor

(Jurors nod negatively when asked if they have questions about the instructions.)

Objections

None recorded
Proceeding 8416 • 7 utterances
Civil Trial
Department 103
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📂 DEC 3, 1996 📄 Jury instruction: evidence and
DEC 3, 1996 KRT DvH TD