📄 Motion: prior incidents evidence — Monday, March 13, 1995
Address:
C:\DEPT103\CRIMINAL\1995\MAR\13\MOTION-PRIOR-INCIDENTS-EVIDENC.DOC
TRIAL
▲ Day 36 of 167

Motion: prior incidents evidence

Date: Monday, March 13, 1995 • Utterances: 54
F. Lee Bailey argued that the prosecution's tactical decision to elicit on direct examination Fuhrman's 1985 contact with the Simpsons and his special sensitivity training constituted a 'preemptive strike' that opened the door to the previously-excluded 1981 psychiatric reports documenting Fuhrman's racial attitudes. Marcia Clark countered that the prosecution's direct examination choices changed nothing about the court's earlier evidentiary ruling and that the defense had never provided any offer of proof that Fuhrman planted evidence. Judge Ito denied the motion, ruling the previous ruling would stand.
1 (THE FOLLOWING PROCEEDINGS WERE HELD IN OPEN COURT, OUT OF THE PRESENCE OF THE JURY:)
2 THE COURT:

BACK ON THE RECORD IN THE SIMPSON MATTER. ALL THE PARTIES ARE AGAIN PRESENT. COUNSEL, IS THERE ANYTHING WE NEED TO TAKE UP BEFORE WE INVITE THE JURORS TO REJOIN US?

3 MS. CLARK:

YES, YOUR HONOR.

4 THE COURT:

MISS CLARK.

5 MS. CLARK:

WELL, THIS IS A MOTION PRESENTED BY MR. BAILEY.

6 THE COURT:

ALL RIGHT. I -- WHAT I PROPOSE WE DO IS, WHY DON'T YOU TAKE A LOOK AT IT OVER THE NOON HOUR, AND WE'LL TAKE IT UP. I ACCEPT MR. BAILEY'S REPRESENTATION OFF THE RECORD THAT HE WILL NOT GO INTO THOSE AREAS TODAY.

7 MS. CLARK:

BUT THAT DOESN'T ADDRESS THE PEOPLE'S CONCERN. IF THE COURT IS INCLINED TO RULE IN DEFENSE FAVOR, WHICH THE PEOPLE SEE NO REASON FOR THE COURT TO DO, THE PEOPLE -- WE HAVE READ THE MOTION AND THE REASONS THAT GENERATED THE MOTION AND WE SEE NO MERIT TO THE REQUEST.

NEVERTHELESS, IF THE COURT DOES IN -- DOES INTEND TO RULE IN THE DEFENDANT'S FAVOR WITH RESPECT TO THE PERIMETERS OF CROSS-EXAMINATION, THE PEOPLE ARE ENTITLED TO KNOW ABOUT THIS ONE BEFORE WE FINISH DIRECT BECAUSE THESE WERE ITEMS THAT THE PEOPLE RAISED IN THE PEOPLE'S MOTION. THE COURT ISSUED A RULING, AND BASED ON THAT, WE MADE A DECISION AS TO HOW WE WOULD PROCEED WITH DIRECT. IF THE COURT IS NOW GOING TO CHANGE THAT --

8 THE COURT:

WELL, LET ME -- LET ME -- EXCUSE ME FOR INTERRUPTING YOU. DO YOU WANT TO LITIGATE IT NOW?

9 MS. CLARK:

YES.

10 THE COURT:

OKAY. I LEFT IT ON MY DESK. MISS ROBERTSON.

11 (BRIEF PAUSE.)
12 THE COURT:

THANK YOU. ALL RIGHT. MR. BAILEY, DO YOU WISH TO BE HEARD?

13 MR. BAILEY:

YES, YOUR HONOR. YOU WILL RECALL --

14 MS. LEWIS:

YOUR HONOR, EXCUSE ME. IF WE COULD HAVE A MOMENT. I DON'T KNOW IF DEFENSE WANTED DETECTIVE FUHRMAN PRESENT.

15 THE COURT:

ALL RIGHT. DETECTIVE FUHRMAN, COULD WE ASK YOU TO STEP OUTSIDE, PLEASE? THANK YOU. (DETECTIVE FUHRMAN EXITS THE COURTROOM.)

16 THE COURT:

ALL RIGHT. RECORD SHOULD REFLECT THAT DETECTIVE FUHRMAN HAS WITHDRAWN FROM THE COURTROOM. MR. BAILEY.

17 MR. BAILEY:

YOUR HONOR, WE HAVE VISITED THIS SUBJECT ON SEVERAL OCCASIONS UNDER THE UMBRELLA OF THE MANDATE OF THE ANTHONY CASE DECIDED IN THIS DISTRICT. YOU HAD ISSUED A RULING BARRING CERTAIN EVIDENCE OF STATEMENTS MADE TO PSYCHIATRISTS, REPORTS OF PSYCHIATRISTS IN CONNECTION LITIGATION INSTITUTED BY MR. FUHRMAN IN THE EARLY 80'S CLAIMING A DISABILITY BECAUSE OF CERTAIN EXPERIENCES HE HAD HAD. AND AT THE TIME THAT YOU ISSUED THAT RULING, IT WAS REPRESENTED TO THE COURT THAT MR. FUHRMAN WOULD NOT BE A WITNESS TO THE 1985 INCIDENT INVOLVING THE MERCEDES BENZ WINDSHIELD AND THAT HE WOULD NOT BE INVOLVED IN THE 1989 INCIDENT WHICH IN FACT WENT TO COURT. NOW, THE PROSECUTION OPENED RIGHT UP WITH THAT. IN ADDITION, THIS IS A FIRST IN MY EXPERIENCE, THEY OPENED UP WITHOUT SPECIFYING THAT HE HAD BEEN SUBJECTED TO SOME KIND OF SPECIAL TRAINING SESSION THAT HAD NOTHING TO DO WITH THE MURDERS AT BUNDY OR THE EVIDENCE AT ROCKINGHAM. AND IT SEEMS TO ME THAT THE QUESTION OF MR. FUHRMAN'S GLOBAL ATTITUDES TOWARD RACE SPECIFICALLY AND IN PARTICULAR COUPLES THAT ARE RACIALLY MIXED SUCH AS MR. SIMPSON AND NICOLE IS FAIR GAME FOR QUESTIONING IN AS MUCH AS HE IS VERY DEFINITIVELY A SUSPECT FOR HAVING CARRIED THAT GLOVE FROM BUNDY WHERE HE FOUND IT TO ROCKINGHAM WHERE HE DEPOSITED IT, AND THAT'S WHAT WE INTEND TO SHOW BY CIRCUMSTANTIAL EVIDENCE FAR STRONGER THAN THE PEOPLE WILL EVER OFFER AGAINST O.J. SIMPSON ON THE MURDERS. IF MOTIVE AND OPPORTUNITY ARE THE MEANS THAT THE PEOPLE USE TO PROVE THE GUILT OF THE DEFENDANT, WHICH THEY SAY THEY CAN DO, THAT IS A FAIR METHOD TO PROVE THE INNOCENCE OF THE DEFENDANT BY SHOWING THAT HE WAS FRAMED. THE OPPORTUNITY WILL BE PATENT IF IT IS NOT ALREADY ON THE RECORD BY THE TIME MR. FUHRMAN'S CROSS-EXAMINATION IS COMPLETE. THE MOTIVE, ONE THAT WOULD INCLINE A POLICE OFFICER TO DO SOMETHING THIS DRASTIC EVEN THOUGH HE HAD NO WAY OF KNOWING PRESUMABLY WHETHER OR NOT SIMPSON WAS IN TIMBUKTU AT THE TIME HE WAS AT ROCKINGHAM FIRST IS CERTAINLY VERY HIGHLY RELEVANT. IF IT IS EMBARRASSING, IT IS EMBARRASSMENT OF HIS OWN CREATION. HE IS THE ONE THAT CREATED THESE PSYCHIATRIC REPORTS AND CAUSED THEM TO BE FILED PUBLICLY HOPING TO GAIN AS A RESULT. INSOFAR AS THE ORIGINAL CONCERN THAT YOUR HONOR HAD AS TO REMOTENESS IS CONCERNED, I ASK YOUR HONOR TO LOOK AT THE RULINGS THAT WERE MADE WITH RESPECT TO SPOUSAL ABUSE AND THE TIME BRACKETS THAT THE PROSECUTION WAS PERMITTED TO COVER. OF SPECIAL SIGNIFICANCE IS THE FACT THAT DETECTIVE FUHRMAN'S OWN EXPERT OPINED IN THE REPORTS THAT YOU HAVE REVIEWED THAT HIS ANTI-RACIAL FEELINGS WERE INCURABLE AND THAT THERE WAS NO WAY THAT HE COULD CONTINUE TO BE AN EFFECTIVE POLICE OFFICER BECAUSE OF THAT. AND IF THAT CONDITION IS SHOWN TO EXIST, THEN IT SEEMS TO ME THAT THE BURDEN OF GOING FORWARD MAY SHIFT TO THE WITNESS TO SHOW WHEN AND IF SUCH A CURE TOOK PLACE BECAUSE WE INTEND TO SHOW AN INCIDENT AFTER INCIDENT THAT DETECTIVE FUHRMAN WAS WILLING TO VIOLATE THE LAW AND THE FEDERAL CIVIL RIGHTS STATUTE TO UNFAIRLY PROSECUTE BLACK MEN WHO HE FOUND IN THE COMPANY OF WHITE WOMEN AND THAT THIS PATTERN WAS CONSISTENT RIGHT UP UNTIL SHORTLY BEFORE THIS INCIDENT. BASED ON ALL OF THOSE FACTS, THE STARTING POINT -- AND WE'RE NOT SEEKING AT THIS POINT TO GO BACK TO HIS MARINE CORPS EXPERIENCES WHICH ARE OUT THERE, BUT THE STARTING POINT WHICH RELATE TO THOSE AND WHY HE WANTED TO GET OUT OF THE MARINE CORPS BECAUSE HE COULD NOT STAND THE DEFIANCE THAT MINORITY GROUPS WERE HANDING HIM WHEN HE GAVE THEM DIRECTION AND WHY HE WANTED TO GET OUT OF THE POLICE FORCE BECAUSE HE COULDN'T TAKE THE CONDUCT OF THE PEOPLE HE HAD TO DEAL WITH IS PART OF A TOTAL PERSONALITY PICTURE THAT THIS JURY IS ENTITLED TO EVALUATE BECAUSE ULTIMATELY, THEY'RE GOING TO HAVE TO EVALUATE THE QUESTION AS TO WHETHER OR NOT THIS OFFICER INCENSED THAT BEING KICKED OFF THE BIGGEST MURDER CASE IN THE HISTORY OF THIS STATE DECIDED TO KEEP HIMSELF IN IT BY BECOMING AN INDISPENSABLE WITNESS AS HE SURELY HAS DONE. THAT IS OUR PRESENTATION, AND IN THAT CONTEXT, I THINK WE'RE ENTITLED TO HAVE THE COURT RECONSIDER ITS EARLIER RULING THAT THE PSYCHIATRIC REPORTS ARE VERBOTEN. THANK YOU.

18 THE COURT:

MISS CLARK.

19 MS. CLARK:

YES, YOUR HONOR. I DON'T REALLY THINK THE COURT NEEDS TO HEAR A LOT FROM THE PEOPLE. THE DEFENSE HAS REALLY NOT OFFERED YOU ANY REASON TO CHANGE THE EARLIER RULING THAT YOU'VE ISSUED. WHAT THEY'RE BASICALLY ARGUING TO THE COURT IS THAT THE FACT OF THE COURT'S PERMISSION FOR THE DEFENSE TO USE THE KATHLEEN BELL ALLEGATIONS, WHICH WE WILL DISPROVE, NEVER THE LESS, THE FACT THAT THE COURT ISSUED THAT RULING IS NOW BASICALLY BEING POSITED TO THE COURT AS AN EXCUSE TO GO BACK INTO THE VERY ITEMS THAT THE COURT RULED TO BE TOO REMOTE AND INADMISSIBLE. THE FACT THAT THE PEOPLE DECIDED TO AIR THOSE INCIDENTS THAT THE DEFENSE HAS BEEN THREATENING TO USE AGAINST DETECTIVE FUHRMAN BY WAVING THE NEWSWEEK ARTICLE BACK IN CHAMBERS ABOUT THE MOCK CROSS-EXAMINATION, BY THE DISCUSSIONS AND THE NIGHTLY PRESS CONFERENCES CONCERNING KATHLEEN BELL AND HER CREDIBILITY AND HOW THEY'RE GOING -- WHAT THEY'RE GOING TO PROVE VIA KATHLEEN BELL, THE PEOPLE DETERMINED AS A TACTICAL MATTER TO BASICALLY DO A PREEMPTIVE STRIKE AND AIR THOSE MATTERS FIRST ON DIRECT EXAMINATION. BUT THAT DOESN'T OPEN A DOOR ANY FURTHER THAN IT WAS ALREADY OPENED BY THE COURT'S RULING. THE COURT RULED THAT CERTAIN THINGS WOULD BE ADMISSIBLE. IT RULED THAT THE KATHLEEN BELL INCIDENT WAS ADMISSIBLE. IF IT WAS INCLINED TO -- IF YOU WERE INCLINED TO ALLOW THE '81 INCIDENT, YOU WOULD HAVE DONE SO. BUT THE MERE FACT THAT YOU ALLOWED THE DEFENSE TO GO INTO THE '85 INCIDENT AND THEN THE PEOPLE AIR IT ON DIRECT KNOWING THAT THE COURT IS GOING TO ALLOW THE DEFENSE TO DO SO ON CROSS-EXAMINATION DOESN'T OPEN THE DOOR ANY FURTHER THAN IT WAS TO BEGIN WITH.

YOU ISSUED A RULING. YOU SAID A CERTAIN INCIDENT WAS ADMISSIBLE AND THE DEFENSE COULD GO INTO IT ON CROSS-EXAMINATION. THE PEOPLE WERE AWARE OF THAT RULING, BUT THE PEOPLE WERE ALSO AWARE THAT THE COURT RULED THAT THE '81 INFORMATION COULD NOT BE AIRED. I DON'T SEE HOW THERE'S ANY DIFFERENT POSTURE NOW SIMPLY BECAUSE OF THE FACT THAT WE DISCUSSED IT ON DIRECT EXAMINATION. AND THE COURT HAS NOT GIVEN NOTABLY ANY RELEVANT CASE AUTHORITY TO JUSTIFY THIS POSITION. IT'S SIMPLY COUNSEL'S BALD ASSERTION. WHEN YOU CONSIDER THE FACT THAT THE DEFENSE HAS NEVER AND WILL NEVER BE ABLE TO DEMONSTRATE EITHER THE OPPORTUNITY OR THE -- OR GIVE ANY KIND OF REAL OFFER OF PROOF TO THIS COURT THAT DETECTIVE FUHRMAN PLANTED ANYTHING, IT'S REALLY -- AND YET THEY GOT THE 1985 INCIDENT FOR -- AS RISK FOR THEIR CROSS-EXAMINATION MILL, I REALLY THINK THEY'VE GONE -- IT'S ALREADY BEYOND THE PALE. THEY HAVE -- THEY WILL NEVER BE ABLE TO GIVE THIS COURT AN OFFER OF PROOF. THEY HAVEN'T TO THIS DATE WHEN THE PEOPLE HAVE REQUESTED THAT THEY DO SO, GIVE US AN OFFER OF PROOF, SHOW US HOW YOU'RE GOING TO PROVE THAT THIS DETECTIVE PLANTED THIS EVIDENCE.

THEY HAVE NOT ONCE, NOT ONCE BEEN ABLE TO DO SO. THEY HAVE REFUSED TO DO SO, AND THE REASON THEY REFUSED TO DO SO IS THEY CAN NOT. THERE WILL NEVER BE SUCH EVIDENCE BECAUSE IT'S AN IMPOSSIBILITY. AND EVEN THOUGH THERE WAS NO OPPORTUNITY AND IT'S A VIRTUAL IMPOSSIBILITY FOR THEM TO HAVE DONE WHAT THEY ALLEGE THAT DETECTIVE FUHRMAN HAS DONE, YET THEY GOT THE RULING FROM THE COURT, WHICH IS VERY GENEROUS, ALLOWING THE 1985 INCIDENT FOR IMPEACHMENT. TO NOW ARGUE THAT THAT VERY RULING WHICH THE PEOPLE ACTED UPON ALLOWS THEM TO GO FURTHER IS LUDICROUS, IS WITHOUT AUTHORITY AND WITHOUT LOGIC.

20 THE COURT:

FORGIVE ME FOR INTERRUPTING YOU, MISS CLARK, BUT DON'T YOU THINK THAT A PRIOR RELATIONSHIP OR PRIOR MEETING BETWEEN THE INTERESTED PARTIES, NICOLE BROWN SIMPSON, THE DEFENDANT AND A KEY PROSECUTION WITNESS -- YOU SAY THAT'S A GENEROUS RULING?

21 MS. CLARK:

NO. I'M NOT TALKING ABOUT THAT. I WAS TALKING ABOUT THE KATHLEEN BELL INCIDENT.

22 THE COURT:

WE'RE SPEAKING OF THE 1985 INCIDENT.

23 MS. CLARK:

EXCUSE ME.

24

(DISCUSSION HELD OFF THE RECORD BETWEEN THE DEPUTY DISTRICT ATTORNEYS.) MS. CLARK: I'M SORRY. THE FACT THAT THE -- THAT DETECTIVE FUHRMAN RESPONDED TO THE '85 INCIDENT IS NOT -- WAS -- IT WAS NOT A SIGNIFICANT EVENT AT THE TIME; IN FACT, SO INSIGNIFICANT THAT IT WAS -- HE DID NOT GENERATE A REPORT. HE SIMPLY RESPONDED TO THE LOCATION, WAS CERTAINLY NOT THE ONLY OFFICER TO DO SO. AND WE WILL HEAR FROM THAT OTHER OFFICER LATER ON IN THE CASE WHO WAS ALSO PRESENT AT THE SCENE. BUT THAT IN AND OF ITSELF WAS OBVIOUSLY NOT A GREAT EVENT, YOU KNOW, AND IT WAS NOT SOMETHING THAT HE EVEN REMEMBERED UNTIL REQUESTED TO REPORT ON A PRIOR INCIDENT BACK IN '89.

25 THE COURT:

NO. I WAS JUST CONCERNED ABOUT YOUR CHARACTERIZATION OF THAT AS BEING A GENEROUS, QUOTE, UNQUOTE RULING. I THOUGHT I WAS PRETTY MUCH COMPELLED TO ALLOW THE JURY TO HEAR THAT THERE WAS SOME PRIOR CONTACT AMONGST THESE PARTIES.

26 MS. CLARK:

THAT'S TRUE. I'M NOT ARGUING THAT. I WAS ARGUING THE KATHLEEN BELL INCIDENT, JUST THE BELL INCIDENT, YOUR HONOR.

27 THE COURT:

ALL RIGHT.

28 MS. CLARK:

THAT WAS THE ONLY ONE. AND --

29 THE COURT:

BUT MR. BAILEY MAKES THE ARGUMENT THAT SINCE WE HAVE GONE IN AT SOME LENGTH THE '85 INCIDENT, THAT THEN THEY'RE ALLOWED TO GO INTO THE -- THEY SHOULD BE ALLOWED TO GO INTO THE '81 ISSUES.

30 MS. CLARK:

AND I UNDERSTAND. AND I THINK THE ARGUMENT HAS ABSOLUTELY NO MERIT. THERE'S NO CASE AUTHORITY TO JUSTIFY IT, THERE'S NO LOGIC TO JUSTIFY IT. THEY ARE IN NO DIFFERENT POSITION NOW THAN WHEN THE COURT RULED EARLIER. THE SAME INFORMATION WAS DEEMED ADMISSIBLE THEN AS IS NOW. THE COURT MADE A RULING SAYING THAT THE KATHLEEN BELL INCIDENT COULD COME IN. THE DEFENSE WAS AWARE THAT WE WERE GOING TO BE PROVING THE 1985 INCIDENT AND THE DEFENSE WAS VERY CLEAR IN ITS INDICATION THEY WERE GOING TO USE THE PRIOR CONTACT WITH MR. SIMPSON TO TRY AND PAINT A CERTAIN PICTURE OF DETECTIVE FUHRMAN AND HIS ACTIVITIES IN THIS CASE --

31 (DISCUSSION HELD OFF THE RECORD BETWEEN THE DEPUTY DISTRICT ATTORNEYS.)
32 MS. CLARK:

-- WHICH, AS I UNDERSTAND IT, IS PART OF WHAT -- MAY HAVE BEEN PART OF WHY THE COURT ALLOWED THE KATHLEEN BELL EVIDENCE IN. SO THE COURT MADE ITS RULING BASED ON THE FACT OF THE PRIOR CONTACT AND THEN THE CONTENT OF THE KATHLEEN BELL ALLEGATIONS. BUT THE FACT THAT THE PEOPLE ELICITED THIS INFORMATION ON DIRECT PUTS THE DEFENSE IN NO DIFFERENT POSTURE. IT DOESN'T MAKE THE '81 INFORMATION ANY MORE RELEVANT THAN THE COURT EARLIER DEEMED IT. WHAT IS THE CHANGE IN CIRCUMSTANCE? THE COURT MADE A RULING ON WHAT IS ADMISSIBLE. THE PEOPLE ACTED UPON THE RULING. AND SO WHAT IS DIFFERENT? BASED ON THEIR ARGUMENT, YOUR HONOR, IF THEY BROUGHT OUT THE '85 INCIDENT AND THEY BROUGHT OUT KATHLEEN BELL, WHICH OBVIOUSLY THEY WERE GOING TO DO, THEY WOULD THEN BE ABLE TO STAND UP AND SAY TO THE COURT, WELL, NOW THAT WE'VE BROUGHT ALL THIS OUT, WE CAN BRING OUT THE '81 INCIDENT AS WELL. WHAT'S THE DIFFERENCE? SAME THING. I DON'T SEE THE CHANGE IN CIRCUMSTANCE. PERHAPS IF THE COURT DOES, IT COULD GIVE AN INDICATION. BUT OTHER THAN THEIR BALD ASSERTION THAT THEY GOT THIS MUCH AND SO THEREFORE, THEY GET THIS MUCH MORE, THERE'S NO LOGIC AND THERE IS NO CASE AUTHORITY TO SUPPORT THE REQUEST.

33 THE COURT:

WELL, JUST SO WE ALL UNDERSTAND, THE BASIS FOR THE COURT'S RULING ON THE KATHLEEN BELL INCIDENT IS STATED IN THE COURTS'S WRITTEN RULING. HOWEVER, JUST SO WE'RE ALL OPERATING FROM THE SAME SHEET OF INFORMATION, IT'S BECAUSE OF THE ALLEGATION, ONE OF RACIAL BIAS AND, TWO, THE WILLINGNESS TO FABRICATE INFORMATION REGARDING INTER-RACIAL COUPLES.

34 MS. CLARK:

RIGHT.

35 THE COURT:

WHICH IS VERY SPECIFIC TO THE FACTS AND CIRCUMSTANCES AND SIMILARITY TO THIS CASE. SO I FELT COMPELLED TO ALLOW THAT FOR CROSS-EXAMINATION.

36 MS. CLARK:

AND THE PEOPLE ACCEPT THE COURT'S RULING AND WE UNDERSTAND.

37 THE COURT:

OKAY.

38 MS. CLARK:

AND ALL I'M SAYING IS, BY VIRTUE OF THAT RULING, THE DEFENSE DOES NOT NOW GET TO GO AND SAY WELL, NOW THE DOOR IS OPEN WIDE. NO, THE COURT HAS ALREADY INDICATED HOW FAR THE DOOR IS OPEN AND IT DOESN'T GET OPEN ANY FURTHER BECAUSE BY VIRTUE OF ITS OWN RULING. IT'S KIND OF A WEIRD ILLOGICAL ARGUMENT. I CAN NOT -- THE PEOPLE FAIL TO SEE ANY MERIT IN IT WHATSOEVER AND OBVIOUSLY THERE'S NO CASE AUTHORITY TO SUPPORT IT. THE PEOPLE URGE THE COURT NOT TO EXTEND THE PERIMETERS ANY FURTHER.

39 THE COURT:

ALL RIGHT. THANK YOU, MISS CLARK. MR. BAILEY, ANY RESPONSE?

40 MR. BAILEY:

JUST THIS RESPONSE, YOUR HONOR. FIRST, YOU WILL RECALL THAT MISS CLARK WENT TO GREAT PAINS TO ELICIT FROM DETECTIVE FUHRMAN ALL OF THE THINGS HE COULD HAVE DONE TO MR. SIMPSON IN 1985, AS IF HE HAD THE RIGHT TO ARREST HIM, PAT HIM DOWN, INTERROGATE HIM, FOLLOW UP ON THE CASE TO SHOW A LACK OF ANIMUS.

NOW, THAT'S GRABBING THE BULL BY THE HORNS. THE WORD "PREEMPTIVE STRIKE" IN THE TRIAL OF CASES IS SPELLED W-A-I-V-E-R, AND THAT'S TRUE IN THIS CASE. FURTHERMORE, IN THE EXTRAORDINARY SET OF CIRCUMSTANCES WHERE THE PROSECUTION FELT COMPELLED TO ACQUAINT THE JURY WITH THE FACT THAT THIS WITNESS REQUIRED SPECIAL TRAINING SO HE COULD CONTROL HIMSELF ON THE WITNESS STAND, WE'RE ENTITLED TO SHOW WHY THAT SPECIAL TRAINING WAS AND ALWAYS WILL BE NECESSARY IN HIS CASE. AND I THINK THEY HAVE OPENED THE DOOR WIDE. YOU CAN'T JUST CHANGE THE RULES BASED ON A COURT'S RULING WHICH REFLECTS OTHER BASES AND THEN SAY, BUT WE DON'T WANT TO PAY A PENALTY FOR THAT. THEY TOOK THE BIT AND I THINK THAT THE DEFENSE IS ENTITLED TO WALK THROUGH THE CAVERNOUS DOOR THAT THEY'VE OPENED.

41 THE COURT:

ALL RIGHT. THANK YOU, COUNSEL. LET ME JUST ASK MISS CLARK ONE FOLLOW-UP QUESTION. IT'S YOUR POSITION THAT IF THE COURT WERE TO GRANT THIS WIDER RANGE OF INQUIRY, YOU WOULD WANT TO REOPEN, CORRECT?

42 MS. CLARK:

YES.

43 THE COURT:

ALL RIGHT. THANK YOU. (BRIEF PAUSE.)

44 MR. BAILEY:

EXCUSE ME, YOUR HONOR. MIGHT I ADD ONE THING?

45 THE COURT:

ONLY AT THE RISK OF OPENING THE DOOR FOR MISS CLARK TO RESPOND.

46 MR. BAILEY:

I REALIZE THAT THAT'S A SUBSTANTIAL RISK, BUT I LEFT OUT SOMETHING THAT I THINK IS EXTREMELY SIGNIFICANT; AND THAT IS THE PEOPLE DISPLAYING TO THE JURY THE BELL LETTER. THEY CHOSE TO DO THAT. THEY CHOSE TO PUT THOSE WORDS IN THE JURY BOX, AND I THINK THAT THAT OUGHT TO BE CONSIDERED AT LEAST BY THE COURT IN DECIDING WHETHER OR NOT THERE HAS BEEN A CHANGE IN CIRCUMSTANCES. THAT'S ALL.

47 THE COURT:

ALL RIGHT. THANK YOU. DO YOU WANT TO RESPOND TO THAT LAST POINT, MISS CLARK?

48 MS. CLARK:

I CAN'T SEE HOW THAT MAKES ANY DIFFERENCE AT ALL UNLESS IF THE COURT THINKS IT DOES, I WILL ADDRESS THE ISSUE. BUT --

49 THE COURT:

NO. THIS IS YOUR OPPORTUNITY TO GIVE ME YOUR -- THE BENEFIT OF YOUR ENLIGHTENMENT.

50 MS. CLARK:

I WOULD BE DELIGHTED TO DO SO, BUT ONLY IF REQUIRED TO DO SO. I DON'T NEED TO BURDEN THE COURT WITH MORE STATEMENTS. I DON'T SEE ANYTHING -- ANY MERIT IN THE ADDITIONAL COMMENTS OF MR. BAILEY. I THINK THAT -- IT MAKES NO DIFFERENCE. AND IF THE COURT THINKS IT DOES, I WILL ADDRESS THAT POINT. DOES THE COURT --

51 MR. BAILEY:

I OBJECT TO THE COURT PREVIEWING ITS RULING SO MISS CLARK CAN DECIDE WHETHER OR NOT AN ARGUMENT IS NECESSARY.

52 THE COURT:

NO. I THINK IT'S JUST A VERY CLEVER WAY TO ADDRESS THESE MATTERS. MISS CLARK, ACTUALLY THE OPTION IS, IF YOU WANT TO ADDRESS IT, FINE. IF NOT, FINE.

53 MS. CLARK:

I WOULD THEN JUST SIMPLY TELL THE COURT IT MAKES NO DIFFERENCE. KATHLEEN BELL IS -- IT WAS AIRED THROUGH TESTIMONY, WHETHER IT'S WITH THE LETTER OR NOT.

54 THE COURT:

ALL RIGHT. ALL RIGHT. THE COURT'S PREVIOUS RULING WILL STAND. LET'S PROCEED. ALL RIGHT. DEPUTY MAGNERA, LET'S HAVE THE JURORS, PLEASE. AND, DEPUTY BROWNING, CAN I HAVE DETECTIVE FUHRMAN BACK, PLEASE.

Temperature

tense

Key Quotes (5)

F. Lee Bailey
THE WORD 'PREEMPTIVE STRIKE' IN THE TRIAL OF CASES IS SPELLED W-A-I-V-E-R, AND THAT'S TRUE IN THIS CASE.
Bailey's sharpest rhetorical thrust — arguing the prosecution's tactical decision to air Fuhrman's prior incidents on direct was a legal waiver that widened the permissible scope of cross-examination.
F. Lee Bailey
DETECTIVE FUHRMAN'S OWN EXPERT OPINED IN THE REPORTS THAT YOU HAVE REVIEWED THAT HIS ANTI-RACIAL FEELINGS WERE INCURABLE AND THAT THERE WAS NO WAY THAT HE COULD CONTINUE TO BE AN EFFECTIVE POLICE OFFICER BECAUSE OF THAT.
The core of Bailey's argument for admitting the psychiatric reports — Fuhrman's own psychiatrist declared his racism permanent and professionally disqualifying.
F. Lee Bailey
I THINK THEY HAVE OPENED THE DOOR WIDE. YOU CAN'T JUST CHANGE THE RULES BASED ON A COURT'S RULING WHICH REFLECTS OTHER BASES AND THEN SAY, BUT WE DON'T WANT TO PAY A PENALTY FOR THAT. THEY TOOK THE BIT AND I THINK THAT THE DEFENSE IS ENTITLED TO WALK THROUGH THE CAVERNOUS DOOR THAT THEY'VE OPENED.
Bailey's 'cavernous door' formulation — vivid framing of the open-door doctrine that the court ultimately rejected.
Lance A. Ito
IT'S BECAUSE OF THE ALLEGATION, ONE OF RACIAL BIAS AND, TWO, THE WILLINGNESS TO FABRICATE INFORMATION REGARDING INTER-RACIAL COUPLES... WHICH IS VERY SPECIFIC TO THE FACTS AND CIRCUMSTANCES AND SIMILARITY TO THIS CASE.
Ito explains on the record exactly why he allowed Kathleen Bell — two specific grounds (racial bias + fabrication against interracial couples), anchoring the ruling's limits.
Marcia Clark
THEY WILL NEVER BE ABLE TO GIVE THIS COURT AN OFFER OF PROOF. THEY HAVEN'T TO THIS DATE WHEN THE PEOPLE HAVE REQUESTED THAT THEY DO SO, GIVE US AN OFFER OF PROOF, SHOW US HOW YOU'RE GOING TO PROVE THAT THIS DETECTIVE PLANTED THIS EVIDENCE. THEY HAVE NOT ONCE, NOT ONCE BEEN ABLE TO DO SO.
Clark hammers the defense's failure to provide an offer of proof on the planting theory — her strongest substantive counter-argument.

Evidence (6)

Informal
Fuhrman's 1981 psychiatric reports from his disability litigation, in which his own expert opined his anti-racial feelings were incurable
disputed — defense seeks to admit, court previously excluded, motion denied
Informal
1985 incident involving Nicole Simpson and the Mercedes Benz windshield, to which Fuhrman responded
discussed as basis for Bailey's open-door argument; previously admitted for cross-examination
Informal
Kathleen Bell allegations — that Fuhrman expressed racial animus toward interracial couples
discussed; previously ruled admissible for cross-examination
Informal
Kathleen Bell letter, physically displayed to the jury by the prosecution
referenced by Bailey as an additional reason the door was opened wider
Informal
Special sensitivity training Fuhrman underwent — elicited by prosecution on direct
cited by Bailey as prosecution opening the door to the underlying psychiatric history
Informal
1989 incident involving Fuhrman that went to court
mentioned by Bailey as having been represented as outside Fuhrman's testimony when original ruling was issued

Notable Exchanges (3)

F. Lee BaileyLance A. Ito
Bailey's extended argument that the prosecution's 'preemptive strike' on direct — covering the 1985 incident, Kathleen Bell, and special training — constitutes a waiver entitling the defense to 'walk through the cavernous door.' Ito listens fully before ruling against him.
strategic
Lance A. ItoMarcia Clark
Ito interrupts Clark to push back on her characterization of allowing the 1985 incident as a 'generous ruling,' noting he felt compelled to admit evidence of prior contact between Fuhrman and the Simpsons. Clark clarifies she was speaking only about the Kathleen Bell ruling.
revealing
F. Lee BaileyLance A. ItoMarcia Clark
Bailey asks to add one final point about the Bell letter being displayed to the jury; Ito warns it risks giving Clark another turn; Clark declines to argue it matters; Bailey objects to the court seeming to preview its ruling to help Clark decide whether to respond.
strategic

Light Moments (1)

Lance A. Ito
When Bailey asked to add one more point, Ito dryly warned: 'ONLY AT THE RISK OF OPENING THE DOOR FOR MISS CLARK TO RESPOND.' — a judicial joke that used the very legal doctrine under debate.

Credibility Attacks (1)

⚔ Mark Fuhrman
prior psychiatric history, pattern of racial bias
Bailey argued the 1981 psychiatric reports — in which Fuhrman's own expert found his anti-racial feelings 'incurable' — should be admitted to establish motive for planting the Bundy glove at Rockingham. The court denied the motion, maintaining its prior ruling excluding that material.

Witness Demeanor

(DETECTIVE FUHRMAN EXITS THE COURTROOM.) — Fuhrman was asked to leave before the motion was argued so the defense could speak freely.

Objections

1 objections (0 sustained, 0 overruled)
Proceeding 5263 • 54 utterances
Criminal Trial
Department 103
⚖️ Start
📂 MAR 13, 1995 📄 Motion: prior incidents eviden
MAR 13, 1995 KRT DvH TD