Closing Statement – George Graham Vest On Man's Best Friend

October 31, 2011

While surfing the net, occasionally I come across interesting and sometimes fascinating information that does not have much to do with personal injury law but is worth the time to read and upon which to contemplate. As lawyers, we are to put into words our client’s case and sense of loss. We need to convey the core of the case in concise, clear and in words that describe the loss in its full impact to twelve strangers seated in the jury box.

George Graham Vest

George Graham Vest

George Graham Vest gave the following closing argument in 1870 in a lawsuit about a dog named Old Drum, which was shot by a neighbor. It has nothing to do with personal injury cases, but illustrates the point:

“Gentlemen of the jury, the best friend a man has in this world may turn against him and become his enemy. His son or daughter whom he has reared with loving care may prove ungrateful. Those who are nearest and dearest to us — those whom we trust with our happiness and good name — may become traitors in their faith. The money that a man has he may lose. It flies away from him, perhaps when he needs it most. A man’s reputation may be sacrificed in a moment of ill-considered action. The people who are prone to fall on their knees to do us honor when success is with us may be the first to throw the stone of malice when failure settles its cloud upon our heads. The one absolute, unselfish friend that man can have in this selfish world — the one that never proves ungrateful or treacherous –is his dog.”

“Gentlemen of the jury, a man’s dog stands by him in prosperity and poverty, in health and sickness. He will sleep on the cold ground, where the wintry winds blow, and the snow drives fiercely, if only he can be near his master’s side. He will kiss the hand that has no food to offer; he will lick the wounds and sores that come in encounter with the roughness of the world. He guards the sleep of his pauper master as if he were a prince. When all other friends desert, he remains. When riches take wings and reputation falls to pieces, he is as constant in his love as the sun in its journey through the heavens.”

“If fortune drives the master forth an outcast in the world, friendless and homeless, the faithful dog asks no higher privilege than that of accompanying him to guard against danger, to fight against his enemies. And when the last scene of all comes, and death takes the master in its embrace, and his body is laid away in the cold ground, no matter if all other friends pursue their way, there by his graveside will the noble dog be found, his head between his paws, his eyes sad but open in alert watchfulness, faithful and true even to death.”

Each time I read this aloud, it makes me cry. This is what a truly amazing final closing argument should do–it is timeless and it goes to the core issues. Notice, George Vest did not even mention anything about damages–yet, it is all there.

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