📄 Jury instructions and argument conduct — Friday, September 29, 1995
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▲ Day 164 of 167

Jury instructions and argument conduct

Date: Friday, September 29, 1995 • Utterances: 60
With the jury removed, Judge Ito cautioned Marcia Clark for coming close to improper vouching during her closing argument rebuttal. Barry Scheck argued strenuously that the prosecution had crossed the line by emphasizing their personal ethical obligations and courage, while Clark defended her remarks as a permissible response to Cochran's aggressive argument style and implicit jury nullification appeal.
1 (The following proceedings were held in open court, out of the presence of the jury:)
2 THE COURT:

All right. The record should reflect the jury has withdrawn from the courtroom. Miss Clark, the last comment that you made, "If I thought for a minute there was a conspiracy"--

3 MS. CLARK:

I didn't get to finish it. It would be my obligation to dismiss this case.

4 THE COURT:

We are close. We are close here, counsel.

5 MR. SCHECK:

Your Honor, I would ask an instruction.

6 MS. CLARK:

Your Honor, in view of the--

7 MR. SCHECK:

This has been highly improper.

8 THE COURT:

Wait. Sit down.

9 MR. SCHECK:

I'm sorry.

10 THE COURT:

You are close, Miss Clark. I realize it is not a complete thought, but what you can argue is what the evidence shows. You can argue ethical obligations that Prosecutors have. I'm just cautioning here that you are close here. You are close to the line.

11 MS. CLARK:

Okay, okay.

12 THE COURT:

You are not over it yet. I was--Mr. Scheck.

13 MS. CLARK:

Excuse me. May I just ask for one point of clarification? The thought, as I completed it, is acceptable, is it not?

14 THE COURT:

It is, but every time the "I's" get in there--

15 MS. CLARK:

Yes. Let me just mention this. I have never had a Defense attorney make an argument like Mr. Cochran made, nor have I ever seen a Defense attorney get up and ask for jury nullification in this way.

16 THE COURT:

It was very artfully phrased.

17 MS. CLARK:

I will reserve comment, but what I'm saying, your Honor, is that when a Defense attorney does take the gloves off that way, hit below the belt the way Mr. Cochran does, the law permits us to argue our ethical obligations. The court is aware of that. Under People was Beamon, under U.S. versus Wade, we have the right then to argue what our obligations are. I get to tell the truth, the truth that I have a luxury, they don't have a luxury. I didn't have until I joined this office. They have to represent guilty people and stand you before the jury and say it hasn't been proven, no matter how well it has been proven.

18 MR. COCHRAN:

Objection.

19 THE COURT:

I'm sorry, counsel. You are objecting to her argument to the court?

20 MR. COCHRAN:

Yes, I object to that statement, guilty people. I am objecting to that. I think I have a right to do that, your Honor. I do.

21 MS. CLARK:

Anyway, these are not remarks that I make to the jury, but when counsel takes off the gloves, makes personal attacks the way he has, saying basically that we are criminals, then we have the right under the law to correct that misimpression and to tell the jury we have ethical obligations that prevent us from pursuing a Prosecution unless we believe a hundred percent.

22 THE COURT:

There is the problem.

23 MS. CLARK:

Okay.

24 THE COURT:

Unless you believe the evidence shows it.

25 MS. CLARK:

Okay. Right.

26 THE COURT:

You have to be clear. You cannot infer that you have personal knowledge beyond the state of the evidence.

27 MS. CLARK:

Right. Agreed. No question. I wouldn't do that.

28 THE COURT:

Mr. Scheck.

29 MR. SCHECK:

Your Honor, this--they already have. They have gone over the line. Now, as the court noted, the argument yesterday, and it is one that these Prosecutors have to live with, is that they put Mark Fuhrman on the witness stand, they--he testified in a way about--you know, Mr. Cochran accurately cited the record. He read from it. Talking about how he went through all this terrible personal anguish and all these outside issues were raised and he was presented as a totally credible witness. Now, these Prosecutors have to get up in front of the jury and say he is a racist and a liar. They have to do that because that is what happened. The jury is allowed to consider the fact that they were plainly taken by surprise by the perjury of their own witness. They also have a right to consider the fact that other officers probably knew these facts and never came forward. That is fair argument and fair comment on the evidence. What is unfair argument and unfair comment and clear law is for a Prosecutor to stand up and say that I prosecute police officers, Marcia and I are the ones with courage, and then to go on now and say that she used to be a Defense lawyer and now she is a Prosecutor and she has the luxury of dismissing cases if the evidence is not there and coming forward if she thought something was exculpatory, et cetera, and then vouching personally for the reliability of the evidence, is a highly, highly improper form of argument in this state, every state. They have gone way over the line and it has really got to stop. It has really got to stop. And I don't like to sit here and constantly say, "Objection, objection, objection, objection" to improper forms of argument. And the court is being patient and controlled in terms of overruling it, but this is way, way over the line. I mean, I have been teaching law for eighteen years, and I never heard this kind of stuff, and I dare say that people--I mean, it is amazing. It is amazing. They cannot say it. And what is particularly galling is that they are saying it when they are the ones that have to live with the fact that one of their principle witnesses perjured himself after they put him on. It hurts, but Mr. Cochran's comments with respect to that are fair on the evidence, and trying to vouch in this fashion is improper--improper rebuttal and improper form of argument period.

30 THE COURT:

Mr. Scheck, what I heard also was you can't trust the messengers and you can't trust the message.

31 MR. SCHECK:

Well, those were--

32 THE COURT:

Wait, wait, wait.

33 MR. SCHECK:

Sorry.

34 THE COURT:

And Mr. Darden clearly cast himself as a messenger in his argument. That was a clear, clear shot at the integrity of counsel on this side, and they are entitled to respond.

35 MR. SCHECK:

Wait a second. I think that is incorrect, and please hear me on this. Mr. Cochran's arguments yesterday, Mr. Darden got up and said I'm just the messenger sending you evidence. Mr. Cochran got up and said the messengers in this case are the witnesses. The messengers are mark Fuhrman--oh, he did--and Vannatter. He talked about these messengers being deceivers and that is the argument. Now, I mean, I don't see how the court can allow this kind of vouching if you are inferring that there is some kind of, you know, metaphor cross-over here. Mr. Cochran has a perfect right, it is a total fair comment on the evidence, to talk about these Prosecution witnesses as messengers. If Mr. Darden chooses to cast himself as a messenger, too, well, that is fine, but I didn't interpret that as a comment on Mr. Darden. It was a turn of phrase. And he specifically talked about these witnesses, and to the extent that Mr. Cochran is pointing out that Mark Fuhrman was put up there first as a credible witness and now they have to admit that he is a liar, as he did, and they are distancing themselves, that is fair comment. What is unfair comment is for them to get up here and in this fashion vouch for every other witness and every other piece of evidence in a highly improper form. They have gone way over the line, way over the line.

36 THE COURT:

Cite me a case, counsel, California law dealing with comments of counsel.

37 MR. SCHECK:

Well, your Honor, you have discretion here and we all know the basic principles.

38 THE COURT:

I have cautioned and I have cautioned and I have cautioned them, counsel. Well, the California state bar is a bar that is unto itself and has its own rules.

39 MR. SCHECK:

I have read the code on this case and I understand that you can say what you can't say in other jurisdictions about showing screens and the rest of it, but in this jurisdiction and in every other jurisdiction there are rules about vouching and they have gone over that line.

40 THE COURT:

Well, here is the problem.

41 MR. SCHECK:

We want an instruction.

42 THE COURT:

No, counsel.

43 MR. SCHECK:

The court should at least give a balancing instruction at this point to the jury that it is not the Prosecutor's personal views or personalities or anything else about the evidence that govern; it is their view of the evidence and they should take that.

44 THE COURT:

All right.

45 MR. SCHECK:

I think we are entitled to an instruction like that at this point.

46 THE COURT:

What a Prosecutor may not do as a Prosecutor, may not express personal opinion or belief in a Defendant's guilt where there is some substantial danger that the jurors will interpret this as being based upon information beyond the evidence produced at trial. I have not heard that yet.

47 MR. SCHECK:

Well, that is--that is a different--that is a different improper form of argument, and I think actually Mr. Darden was pretty close to that when he was talking about everybody knows and yesterday he was saying things like he's a murderer. I think he actually went over that line. But let's put that aside. What I'm most concerned about--

48 THE COURT:

Are you saying that there is a substantial danger that when a Prosecutor stands up and says that the Defendant accused of murder is a murderer, that that goes over the line?

49 MR. SCHECK:

No, no, no. I'm saying that you just read, in terms of a Prosecutor's obligation, he has got to say things like the evidence shows, we submit, and I think that in terms of rhetoric he went over that line. But let's put that aside. What I'm most concerned about, and the court frankly is not addressing here, the court can't be seriously suggesting that there--that a form of argument that says we are courageous, we know our ethical obligations, we are telling you that this evidence is correct, if I thought there was a conspiracy, I would come forward and tell you, all that, everything they have been doing this morning is an improper form of argument. It is improper vouching. And your Honor, I think you know it, and I think that we have to have an instruction here.

50 THE COURT:

You are close here, Mr. Scheck.

51 MR. SCHECK:

I have made my point, your Honor.

52 THE COURT:

Thank you. All right. Miss Clark, I'm cautioning you, though.

53 MS. CLARK:

I understand, your Honor.

54 THE COURT:

People versus bane 5 cal.3d 839, the court's comments at 848.

55 MS. CLARK:

I am aware.

56 THE COURT:

You are cautioned.

57 MS. CLARK:

Yes, your Honor. I'm going to--

58 THE COURT:

I don't want to hear any more "I's."

59 MS. CLARK:

Right. You won't. I'm ready. I'm ready to say no more "I's."

60 THE COURT:

Deputy Smith.

Temperature

tense

Key Quotes (5)

Marcia Clark
I have never had a Defense attorney make an argument like Mr. Cochran made, nor have I ever seen a Defense attorney get up and ask for jury nullification in this way.
Clark frames her vouching as a justified response to Cochran's closing argument, accusing him of asking the jury to nullify.
Barry Scheck
I have been teaching law for eighteen years, and I never heard this kind of stuff, and I dare say that people--I mean, it is amazing. It is amazing. They cannot say it.
Scheck's most emphatic moment, arguing the prosecution's vouching was unprecedented and clearly improper.
Lance A. Ito
I don't want to hear any more 'I's.'
The judge's succinct bottom line: Clark must stop inserting herself personally into the argument.
Marcia Clark
They have to represent guilty people and stand you before the jury and say it hasn't been proven, no matter how well it has been proven.
Prompted an immediate objection from Cochran; illustrates exactly the kind of personal editorializing Ito was warning against.
Lance A. Ito
You are close here, counsel. You are close to the line.
Ito's repeated refrain — he declines to find a violation but makes clear Clark is on notice.

Notable Exchanges (3)

Marcia ClarkLance A. Ito
Clark attempts to get clarification that her completed thought about dismissing cases if she believed there was a conspiracy would be acceptable; Ito confirms it technically is but warns against personal 'I' framing.
strategic
Barry ScheckLance A. Ito
Scheck delivers an extended, heated argument that the prosecution's vouching was 'way over the line,' citing eighteen years of teaching law; Ito pushes back by noting Darden was also responding to Cochran casting himself as a messenger.
heated
Johnnie CochranMarcia Clark
Cochran objects mid-argument when Clark tells the court defense attorneys 'have to represent guilty people,' and Ito expresses mild amusement that Cochran is objecting to her argument directed at the court rather than the jury.
tense

Light Moments (1)

Lance A. Ito
Ito notes with dry understatement that Cochran's jury nullification argument 'was very artfully phrased,' declining to characterize it more bluntly.

Credibility Attacks (1)

⚔ Mark Fuhrman
prior inconsistent statement / perjury
Scheck argues it is fair comment for Cochran to highlight that the prosecution vouched for Fuhrman as fully credible, only to later have to concede he is a racist and a liar — and that other officers likely knew and stayed silent.

Objections

1 objections (0 sustained, 0 overruled)
Proceeding 7882 • 60 utterances
Criminal Trial
Department 103
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📂 SEP 29, 1995 📄 Jury instructions and argument
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