Example Closing Statements

Below are example closing statements in personal injury trials. Our lawyers have also included a sample PowerPoint presentation we used in a closing argument.

• Wrongful death medical malpractice closing statement (and rebuttal closing)
• Another wrongful death malpractice closing argument (Miller & Zois clients received $10 million verdict)
• Wrongful death accident case closing statement where the jury awarded $8 million to Miller & Zois client
• Auto tort herniated disc contested liability Plaintiff's close
  • Defendant's close
  • UM defense lawyer close
  • Read the entire last day of trial, including the verdict
• Another traffic collision sample from plaintiff and two defense lawyers
• Brain injury car crash
• Yet another
• Defendant's Close
• Co-defendant's closing
• PowerPoint Closing: jurors in 2021 need a complete presentation

Some quick advice on giving a good closing statement. First, do not summarize all of the evidence, particularly in a trial that lasted less than a week. Even the best trial lawyers who write about closings often throw in some trite advice about summarizing the key evidence. But it is just a bad idea. 

Second, view your close as a chance to give jurors that support your client ammunition to argue for her during deliberations.  A good plaintiff's attorney explains why the defense counsel has offered insufficient evidence. 

Third, try to use the specific language of the law given to the jurors by the judge in your closing statement. You will see in our sample closing statements our lawyers frequently blow up the jury instructions.  Jurors want to follow the law. Give them a chance to do so.  "This is the instruction the judge just read to you moments ago..."  

Fourth, be you. There has been some research on what makes lawyers effective in closing arguments. Certain approaches and tactics have tested well. But there has been virtually no research on the attorney's style of delivery and jury receptivity to that style.  So, in that vacuum, just be authentic. 

Finally, make sure the jury understands that the message they send to the community with their verdict is powerful. Maryland follows what lawyers call the "Golden Rule" of trials. This means lawyers cannot urge jurors, either implicitly or explicitly, to place themselves in the position of the plaintiff and to award damages as they themselves would hope to be awarded. 

But this rule does not mean that they cannot consider the community at large when rendering a verdict. Make sure, one way or another, the jury understands the implication to community safety of their decision. That safety rule should encompass more than the issues in your trial.

Finally, this is your best chance and last chance to step out of your suit and be a human being. Talk to the jurors like real people. Look them in the eye. Speak directly to them in plain, simple language. 

Prepare your closing with precise detail but make sure you are speaking as a person from the heart. (This works well in moot court, too. It is a strong contrast because so many students present like robots in moot court.)

Our law firm provides free resources for trial lawyers from the initial workup of the case case all the way to trial.  Litigation process and trial advocacy students who are working up and preparing for a mock trial or moot court will also benefit. 

• Get sample discovery, pleadings, deposition transcripts, etc.
• Get more trial materials to help you prepare for trial (or moot court)
• Review a sample trial transcript
• Review assorted opening statements in a variety of tort case