📄 Sidebar: hypothetical question — Thursday, June 8, 1995
Address:
C:\DEPT103\CRIMINAL\1995\JUN\8\SIDEBAR-HYPOTHETICAL-QUESTION.DOC
TRIAL
▲ Day 91 of 167

Sidebar: hypothetical question

Date: Thursday, June 8, 1995 • Utterances: 18
Defense attorney Shapiro objected to a hypothetical question posed by prosecutor Kelberg to an expert witness, arguing it effectively assumed Simpson's guilt and lacked evidentiary foundation. Judge Ito largely overruled the objection, finding the blood evidence and single set of footprints supported the hypothetical, but ordered the words 'rage' and 'motivated' removed before the question was read back to the jury.
1 (The following proceedings were held at the bench:)
2 THE COURT:

We're over at the sidebar.

3 MR. SHAPIRO:

Your Honor, we would object to the propriety of the hypothetical that's been proffered in that it clearly is saying, assume Mr. Simpson did this, and that is expressing an opinion of counsel. It is not based on any evidence and it has no relevance to the hypothetical whatsoever.

4 THE COURT:

Mr. Kelberg.

5 MR. KELBERG:

Your Honor, if the Court looks at case such as People versus Phillips, which is I think 121 or 122 Cal. App. 3D., regarding hypothetical questions asked of experts regarding whether the Defendant could have done certain things, in this case, a murder of a child, the Court will find that there is no impropriety in doing so. These are hypothetical circumstances. Mr. Simpson's name has not been used. There are inferences within the record from which the jury can find they exist, and so each of the circumstances of this hypothetical--and the doctor is being asked assuming that these hypothetical circumstances are true, how long this struggle may have taken.

6 THE COURT:

Mr. Shapiro.

7 MR. SHAPIRO:

Yes. There is no evidence whatsoever that this was done by one person. His opinion is, it could have been. His opinion is, it also could not have been. So far, the doctor's testimony cannot exclude any human being on the face of the earth who is capable of holding a knife and committing these acts. And there is no evidence of motivation or rage. In fact, just the opposite. The evidence that we showed of Mr. Simpson on the video shows a very calm individual.

8 THE COURT:

Why don't you take out the "Rage" part of it. But I think there is evidence in the record that would support--if you believe the blood evidence, that would support an inference that it's the Defendant at the scene. There's also a single set of footprints that would support the inference that there was only one assailant involved. So I think there's enough facts in the record that would support Mr. Kelberg's hypothetical. But I do find the "Rage" part of it to be not supported by the record at this point.

9 MR. KELBERG:

Your Honor, could I ask the reporter to read the hypothetical back and eliminate the reference to the "rage"? Because if I try and reframe the question, being human, I will not get it reframed in an identical fashion with the one exception of the Court's ruling. And I believe it would be a better way.

10 THE COURT:

All right.

11 MR. KELBERG:

To comply with the Court's--if the reporter can in fact read it back without that part.

12 THE COURT:

Let me just--

13 MR. SHAPIRO:

We would object to the term "motivated."

14 MR. COCHRAN:

Could we hear it up here?

15 THE COURT:

Let me have--we are charging first degree murder. Leave the "motivated" out of there. I was just asking Mrs. Robertson to check with 165 because he was coughing and wiping his eyes, and I just want to make sure--

16 (Brief pause.)
17 THE COURT:

Let's have the court reporter read back the question.

18 (Brief pause.)

Temperature

procedural

Key Quotes (3)

Robert Shapiro
So far, the doctor's testimony cannot exclude any human being on the face of the earth who is capable of holding a knife and committing these acts.
Shapiro articulates the defense's core argument that the expert's testimony is too speculative to implicate Simpson specifically.
Lance A. Ito
If you believe the blood evidence, that would support an inference that it's the Defendant at the scene. There's also a single set of footprints that would support the inference that there was only one assailant involved.
The judge explicitly validates two key prosecution pillars — blood evidence and single-assailant theory — as sufficient to support the hypothetical.
Brian Kelberg
If I try and reframe the question, being human, I will not get it reframed in an identical fashion with the one exception of the Court's ruling.
Practical lawyering — Kelberg asks the reporter to read back the question rather than risk introducing new issues by paraphrasing.

Evidence (3)

Informal
Blood evidence placing defendant at the scene
discussed as factual predicate supporting the hypothetical
Informal
Single set of footprints at the crime scene
cited by judge as supporting inference of a lone assailant
Informal
Video of Simpson appearing calm
cited by Shapiro to rebut any inference of rage or motivation

Notable Exchanges (2)

Robert ShapiroLance A. Ito
Shapiro argued the hypothetical had no evidentiary basis; Ito agreed only partially, stripping 'rage' and 'motivated' but allowing the rest to stand.
strategic
Brian KelbergLance A. Ito
Kelberg cited People v. Phillips to defend the propriety of asking experts hypotheticals about whether a defendant could have committed a crime.
procedural

Objections

2 objections (2 sustained, 0 overruled)
Proceeding 6318 • 18 utterances
Criminal Trial
Department 103
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📂 JUN 8, 1995 📄 Sidebar: hypothetical question
JUN 8, 1995 KRT DvH TD