Closing Argument Below is a sample of a defense closing argument I wrote for the 2009-2010 AMTA case. Instead of being a complete closing, this is more of an outline of points put into some structure. This is especially apparent when the witnesses are covered, which basically becomes bullet points to hit on. It is the nature of closing arguments to be fluid and change with the case that is present. For this reason the below closing argument is used more as a guide than as a concrete template that has to be recited word for word. It begins with a brief introduction with a theme. Then a small portion of the story surrounding the case is presented. The law in the case, framed from the viewpoint of the defense is shown. It then moves to the highlights of the case and the witnesses that is presented in a more argumentative quality as to sway the jury. Finally there is a brief conclusion. Remember always that this is more of a speech than a paper so the words alone do not convey the entire message. More importantly it is the deliver, movements and posture that bring the argument together. Introduction: Your Honor, Opposing Council, Members of the Jury, may it please the Court. No time, no reason, no evidence; this is exactly what you’ve seen in court today. The state has brought charges of murder against Miss Jackie Owens but all you’ve seen is no time, no reason, and no evidence. More importantly though, you have seen reasonable doubt. Story: Members of the Jury, today in court you heard the story of Jacob Bennett, one of the founding partners of the Trifecta Films Entertainment Company. It was shown that on June 16, 2008 he was seen for the last time. Anything more than this is speculation. We do not know exactly what happened on this day, or the days which followed. All we know for sure, the only thing the evidence absolutely supports is that Mr. Bennett’s body was later found, on July 9, 2008, at the Calkins Cliffs. Law: Now we were all here in court today because the State of Midlands is charging Jackie Owens, not only with the murder of her friend Jacob Bennett, but also with the tampering of physical evidence. The State bore the burden of proof throughout today’s trial and had to prove each element of the charges beyond a reasonable doubt. Now this is the highest burden of proof under the law. This means that right now, this very moment, or later, when you move to deliberate, if there is a single, sensible, rational, reasonable doubt as to whether Jackie Owens committed these crimes, then you cannot find in favor of the State. So did the state meet this burden and prove each element beyond a reason doubt? The answer to that question is no, the state failed to meet their burden. As the defense we did not bear any burden in today’s case. We did not have to call any witnesses or present you with any evidence, but we did. We did so that you could see there was no time, no reason, and no evidence. More importantly though you saw that there is reasonable doubt. Witnesses/Case Events: Alex Grace o Jackie Owens was at Alex Grace’s house on the night in question. o Impossible to be at two places at one time. o Alex Grace’s house is on a golf course, which would be one possible link to mud found on the defendant’s car. o Bolsters the alibi of Jackie Owens. Adrian Malone o Can testify to never selling Jackie Owens Xenon headlights, which were supposedly seen on the car identified at the scene. o Shows how difficult it is to change the light bulbs in Mazerattis from the standard color to Xenon. o Testifies to the number of Mazerattis on the roads in Midlands. o Talks about a stolen car from his lot, which was later found stripped at the marina that resembles the car seen at the scene. Jackie Owens o At Alex Grace’s house on the night in question. o Has never installed Xenon headlights in her Maxeratti. o Does not own a gun. o Does not own a boat. o Did not have a reason to kill her good friend and business partner. o Was under no financial stress to kill Jacob Bennett to receive money. Tie all three together under no time, no reason, no evidence, and reasonable doubt. Propose alternate theories for what happened on that night, namely blaming Casey Maxwell, the third partner of Trifecta Entertainment. o Show that Casey had the time and the reason to kill Jacob Bennett. o Show evidence that points to Casey Maxwell as the perpetrator. Closing: Members of the Jury, someone has died, Jacob Bennett, a great citizen of Midlands has died, and this is obviously tragic. But Jacob Bennett’s death, his murder, does not mean that just anyone can pay for this loss. An innocent man should not pay for this loss. Jackie Owens, an innocent woman, cannot pay for this loss. When you leave this room to deliberate, remember; no time, no reason, no evidence. Find Jackie Owens Not Guilty. Thank you.