Sample Closing Statement

Below are sample closing arguments in personal injury cases. We have also included a sample PowerPoint presentation that was used recently in a closing statement in a personal injury case.

• Wrongful death medical malpractice closing statement (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 Defendant
  • Read the entire last day of trial, including the verdict
• Another traffic collision sample from plaintiff and two defense lawyers
• Brain injury car crash
  • Rebuttal (same case)
• Yet another
• Defendant's Close
• Co-defendant's closing
• PowerPoint Closing

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 closing 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 him in during deliberations. Third, try to use the specific language of the law given to the jurors by the judge to your favor. Jurors correctly want to follow the law. Give them a chance to do so.

Also, you need to make sure the jury understands that the message they send to the community with their verdict is powerful. Maryland follows the what people 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 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.

Our law firm provides free resources for trial lawyers working up a case to trial and litigation process and trial advocacy students who are working up and preparing for a mock trial or moot court.

• 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