📄 Prosecutor's argument on domestic violence evidence — Thursday, January 12, 1995
Address:
C:\DEPT103\CRIMINAL\1995\JAN\12\PROSECUTOR-S-ARGUMENT-ON-DOMES.DOC
TRIAL
▲ Day 2 of 167

Prosecutor's argument on domestic violence evidence

Date: Thursday, January 12, 1995 • Utterances: 3
Prosecutor Scott Gordon makes a brief closing argument urging the court to admit domestic violence evidence, arguing by analogy: if prior abuse history is fully admissible without limitation when a battered woman kills her abuser (battered women's syndrome cases), then consistency and justice demand that the same history come in when the batterer is on trial for murder. Gordon frames the exclusion of such evidence as a policy contradiction that would leave Nicole Brown Simpson's life and death incomprehensible to the jury.
1 MR. GORDON:

CAN I FINISH UP REAL QUICK, YOUR HONOR?

2 THE COURT:

ALL RIGHT.

3 MR. GORDON:

YOUR HONOR, THE INFORMATION THAT IS BEING TALKED ABOUT IN THIS CASE MUST -- MUST BE CONSIDERED WITHIN THE LIGHT OF WHAT WE KNOW ABOUT DOMESTIC VIOLENCE AND SPOUSAL ABUSE, ABOUT THE MOTIVES, THE CONNECTIONS, THE PATTERNS. WHAT THE COURT SHOULD CONSIDER, AND WHAT I FIND INTERESTING IN LOOKING AT THESE CASES, IS THERE IS A LOT OF LITERATURE, LEGALLY AND EMPIRICALLY, IN DIFFERENT KIND OF CASES, AND THE SAME IS TRUE WITH REGARD TO PATRICIDE CASES AND SPOUSAL ABUSE -- KILLING CASES, BOTH THE CASES WHERE THE BATTERER, THE MAN, HAS KILLED THE WIFE AND VICE VERSA, AND WHAT IS INTERESTING TO NOTICE, THAT IF THIS WAS A CASE WHERE THE WOMAN WAS ON TRIAL FOR KILLING HER HUSBAND IN SELF-DEFENSE, ALLEGING ESSENTIALLY THE BATTERED WOMEN'S SYNDROME TYPE KILLING CASE, IT IS CLEAR FROM ARIS, DAY, ALL THOSE CASES, THAT ALL OF THIS EVIDENCE WOULD COME IN. AND GOING BACK AS FAR AS POSSIBLE, IN PATRICIDE CASES, IT IS CLEAR THAT WHERE THE ARGUMENT IS THAT WE NEED TO SHOW THIS PATTERN OF ABUSE TO EXPLAIN THIS DEFENSE, THE ENTIRE HISTORY COMES IN, EVERYTHING, WITHOUT REGARD TO ANY OF THE CONCERNS REGISTERED HERE TODAY. AND IT IS INTERESTING TO NOTE THE VARIOUS POSITIONS, THAT WHEN A WOMAN HAS KILLED HER BATTERER, IT IS ARGUED THROUGHOUT THE LITERATURE, LEGAL, EMPIRICAL, SCIENTIFIC LEGAL REVIEW COMMENTARIES, THAT IT IS ABSOLUTELY UNJUST FOR THE TRIER OF FACT TO CONSIDER WHAT HAPPENED IN THAT HOMICIDE WITHOUT THAT HISTORY, EVERY BIT OF THAT HISTORY. AND WHAT IS INTERESTING TO NOTE, THAT IN THOSE CASES IT IS ONLY GOING TO ONE ISSUE, AND THAT IS THE ISSUE OF REASONABLENESS WITH INTENT AND DEGREE GOING TO ONE VERY SMALL ISSUE. AND YET HERE UNDER VERY TRADITIONAL ANALYSIS, WITHOUT EVER GETTING WITHIN -- TO THE INFORMATION WE HAVE DISCUSSED TODAY OF A COMPELLING INFORMATION ABOUT BATTERED WOMAN'S SYNDROME AND THE LIKE AND BATTERERS SYNDROME AND ALL THE SCIENCE SURROUNDING IT, WHICH IS MUCH MORE EXPANSIVE THAN JUST THE BATTERED WOMAN'S SYNDROME, IT IS COMPELLING THAT WHAT HAS OCCURRED TO THAT WOMAN MUST COME IN BEFORE -- BEFORE THE TRIER OF FACT. HER LIFE AND HER DEATH CANNOT BE UNDERSTOOD. AND IF IT IS APPROPRIATE AND JUST FOR A WOMAN WHO HAS ESSENTIALLY ESCAPED THE BATTERING TO HAVE THAT INFORMATION COME BEFORE A TRIER OF FACT, IT IS ABSOLUTELY BY POLICY AND THE LAW IMPERATIVE FOR IT TO COME IN WHEN A WOMAN -- BATTERER IS ON TRIAL. THANK YOU, YOUR HONOR.

Temperature

tense

Key Quotes (3)

Scott Gordon
HER LIFE AND HER DEATH CANNOT BE UNDERSTOOD.
Distills the prosecution's core argument to its emotional and logical core — domestic violence history is not peripheral but essential to the meaning of the homicide.
Scott Gordon
IF IT IS APPROPRIATE AND JUST FOR A WOMAN WHO HAS ESSENTIALLY ESCAPED THE BATTERING TO HAVE THAT INFORMATION COME BEFORE A TRIER OF FACT, IT IS ABSOLUTELY BY POLICY AND THE LAW IMPERATIVE FOR IT TO COME IN WHEN A WOMAN -- BATTERER IS ON TRIAL.
The crux of the symmetry argument: the defense bar routinely argues for full abuse history in battered women cases, so the prosecution is entitled to the same in a batterer-as-defendant case.
Scott Gordon
IT IS INTERESTING TO NOTE THE VARIOUS POSITIONS, THAT WHEN A WOMAN HAS KILLED HER BATTERER, IT IS ARGUED THROUGHOUT THE LITERATURE, LEGAL, EMPIRICAL, SCIENTIFIC LEGAL REVIEW COMMENTARIES, THAT IT IS ABSOLUTELY UNJUST FOR THE TRIER OF FACT TO CONSIDER WHAT HAPPENED IN THAT HOMICIDE WITHOUT THAT HISTORY, EVERY BIT OF THAT HISTORY.
Gordon weaponizes the defense bar's own advocacy in battered women's syndrome literature against them, highlighting ideological inconsistency.

Evidence (2)

Informal
Legal cases ARIS and DAY, cited as precedent for admission of full abuse history in battered women's syndrome defense cases
cited by counsel in argument
Informal
Legal and empirical literature on battered women's syndrome, batterer's syndrome, patricide cases, and spousal abuse killings
cited by counsel in argument

Notable Exchanges (1)

Scott GordonLance A. Ito
Gordon asks permission to finish his argument; Ito grants it with a single 'ALL RIGHT,' after which Gordon delivers an extended solo argument with no further interruption.
procedural

Objections

None recorded
Proceeding 4383 • 3 utterances
Criminal Trial
Department 103
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📂 JAN 12, 1995 📄 Prosecutor's argument on domes
JAN 12, 1995 KRT DvH TD