[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"doc-seo-572596-105":3,"detail-sidebar-cat-1-en-105":74,"doc-detail-572596-en":120},{"code":4,"msg":5,"data":6},0,"ok",{"site_id":7,"language":8,"slug":9,"title":10,"keywords":11,"description":12,"schema_data":13,"social_meta":67,"head_meta":69,"extra_data":71,"updated_unix":73},105,"en","evidentiary-trial-objections-voir-dire-opening-closing-objections-cheat-sheet","Evidentiary Trial Objections - Voir Dire - Opening - Closing Objections Cheat Sheet","","A concise cheat sheet for evidentiary trial objections, organized by voir dire, opening, and closing. It lists common objection types—irrelevant, leading, lack of foundation, calls for speculation, no personal knowledge, ambiguous or compound questions, beyond the scope, and best-evidence violations—along with supporting rules citations. It also covers hearsay and Sixth Amendment issues, unfair prejudice, propensity evidence, improper impeachment, privileged communications, narrative/non-responsive answers, unqualified or incompetent opinions, misstatements of evidence, and common prosecutorial missteps including improper Fifth Amendment commentary and burden shifting.",{"@graph":14,"@context":66},[15,34,49],{"@type":16,"itemListElement":17},"BreadcrumbList",[18,23,27,31],{"item":19,"name":20,"@type":21,"position":22},"https://docshare.wps.com","Home","ListItem",1,{"item":24,"name":25,"@type":21,"position":26},"https://docshare.wps.com/template/","Template",2,{"item":28,"name":29,"@type":21,"position":30},"https://docshare.wps.com/template/letters/","Letters",3,{"item":32,"name":10,"@type":21,"position":33},"https://docshare.wps.com/template/evidentiary-trial-objections-voir-dire-opening-closing-objections-cheat-sheet/572596/",4,{"url":32,"name":10,"@type":35,"author":36,"headline":10,"publisher":39,"fileFormat":42,"inLanguage":8,"description":12,"dateModified":43,"datePublished":43,"encodingFormat":42,"isAccessibleForFree":44,"interactionStatistic":45},"DigitalDocument",{"name":37,"@type":38},"pixelkiddo","Person",{"url":19,"name":40,"@type":41},"DocShare","Organization","application/pdf","2026-10-13",true,{"@type":46,"interactionType":47,"userInteractionCount":4},"InteractionCounter",{"@type":48},"ViewAction",{"@type":50,"mainEntity":51},"FAQPage",[52,58,62],{"name":53,"@type":54,"acceptedAnswer":55},"What are common grounds for objections during voir dire?","Question",{"text":56,"@type":57},"Voir dire objections include irrelevant questions, leading questions, lack of foundation, calls for speculation, and questions requiring personal knowledge that has not been established. Objections also cover ambiguous, confusing, or compound questions and questions beyond the scope of direct testimony.","Answer",{"name":59,"@type":54,"acceptedAnswer":60},"How are hearsay and Sixth Amendment issues treated in evidentiary objections?",{"text":61,"@type":57},"Hearsay objections are raised under evidentiary rules addressing statements offered for the truth of the matter asserted, and they may be tied to Sixth Amendment concerns when the challenged statement is made by someone other than the testifying witness.",{"name":63,"@type":54,"acceptedAnswer":64},"What closing and opening conduct is targeted by objections?",{"text":65,"@type":57},"Objections address arguments or statements in opening that misstate the law or improperly make factual arguments. In closing, objections include relying on facts not in evidence, attacking counsel, personal opinions, prejudicial or inflammatory remarks, improper emotional appeals, improper policy arguments, burden shifting, and improper Fifth Amendment commentary about silence.","https://schema.org",{"og:url":32,"og:type":68,"og:title":10,"og:site_name":40,"og:description":12},"article",{"robots":70,"canonical":32},"index,follow",{"doc_id":72,"site_id":7},572596,1791928351,{"code":4,"msg":75,"data":76},"success",[77,82,87,92,97,102,107,111,116],{"id":78,"doc_module":22,"doc_module_name":25,"category_name":79,"show_sort_weight":80,"slug":81},11,"Presentations",90,"presentations",{"id":83,"doc_module":22,"doc_module_name":25,"category_name":84,"show_sort_weight":85,"slug":86},12,"Resumes",80,"resumes",{"id":88,"doc_module":22,"doc_module_name":25,"category_name":89,"show_sort_weight":90,"slug":91},14,"Invoices",70,"invoices",{"id":93,"doc_module":22,"doc_module_name":25,"category_name":94,"show_sort_weight":95,"slug":96},15,"Posters",60,"posters",{"id":98,"doc_module":22,"doc_module_name":25,"category_name":99,"show_sort_weight":100,"slug":101},16,"Social Media",50,"social-media",{"id":103,"doc_module":22,"doc_module_name":25,"category_name":104,"show_sort_weight":105,"slug":106},17,"Forms",40,"forms",{"id":108,"doc_module":22,"doc_module_name":25,"category_name":29,"show_sort_weight":109,"slug":110},18,30,"letters",{"id":112,"doc_module":22,"doc_module_name":25,"category_name":113,"show_sort_weight":114,"slug":115},21,"Paper Templates",5,"papers-templates",{"id":117,"doc_module":22,"doc_module_name":25,"category_name":118,"show_sort_weight":4,"slug":119},158,"General","general-158",{"code":4,"msg":75,"data":121},{"doc_id":72,"user_id":122,"nickname":37,"user_avatar":123,"doc_module":22,"category_id":108,"category_name":29,"doc_title":10,"doc_description":12,"doc_content":124,"file_id":125,"file_url":126,"file_type":127,"file_size":128,"view_count":4,"is_deleted":4,"is_public":22,"is_downloadable":22,"audit_status":22,"page_count":22,"language":129,"language_code":8,"site_id":7,"html_lang":8,"table_of_contents":130,"faqs":131,"seo_title":132,"seo_description":12,"update_tm":73,"read_time":4},962090883892,"https://ap-avatar.wpscdn.com/avatar/e00115db34f3e0f11b?x-image-process=image/resize,m_fixed,w_180,h_180&k=1790152879550218658","EVIDENTIARY TRIAL OBJECTIONS VOIR DIRE / OPENING / CLOSING OBJECTIONS  \nIRRELEVANT  \n11-401 / 11-402 (no import to the determination of case/elements)  \nLEADING  \n11-611 (C) (question suggests the answer – impermissible on direct)  \nLACK OF FOUNDATION  \n11-602 (no basis for person to know answer established)  \nCALLS FOR SPECULATION  \n11-602 (Witness being asked to guess)  \nNO PERSONAL KNOWLEDGE  \n11-602 (no basis for knowledge)  \nAMBIGUOUS, CONFUSING, VAGUE 11-403 (question not posed in a clear and precise manner)  \nCUMULATIVE EVIDENCE  \n11-403 (topic covered previously)  \nASKED AND ANSWERED  \n11-403 (repetitive question)  \nCOMPOUND QUESTION  \n11-403 (multiple questions within one) )  \nBEYOND THE SCOPE  \n11-611 (Outside of direct testimony)  \nBEST EVIDENCE  \n11-1002 (offered exhibit fails to meet the best evidence rule / not original)  \nLEGAL CONCLUSION  \n11-401 (Witness’ opinion is irrelevant & invades province of the jury)  \nHEARSAY & 6th AMEND  \n11-801, 803, 804, & 6th Amendment (statement made by someone other than the witness testifying and offered to prove the truth of the matter asserted)  \nUNFAIR PREJUDICE  \n11-403 (probative value substantially outweighed by unfair prejudice)  \nARGUMENTATIVE  \n(opinion of questioner in the question)  \nPROPENSITY EVIDENCE  \n11-404 (covers uncharged prejudicial“bad” conduct)  \nASSUMES FACTS NOT IN EVIDENCE  \n(question assumes the truth of a  \nmaterial fact not presented in evidence)  \nIMPROPER IMPEACHMENT  \n(attack on a witness's credibility not within allowable rules)  \nPRIVILEGED (Art 5)  \n(disclosure protected by public policy)(Atty/Dr/Marrital,counselor,clergy,)  \nNARRATIVE/NON-RESPONSIVE  \n11-611 (witness just talking)  \nUNQUALIFIED OPINION  \n11-701 / 702 (answer requires expertise)  \nINCOMPETENCY 11-601 (understand oath, duty to tell truth?)  \nMISSTATES EVIDENCE  \n(Misstates evidence or testimony)  \nVOIR DIRE OBJECTIONS  \nASKS JURY TO PREJUDGE THE FACTS/EVIDENCE  \nQuestions at voir dire are improper if they call for a finding of fact or promise from the jurors to vote a particular way.  \nPREJUDICIAL/INFLAMMATORY  \n(questions prejudice or inflame the jury) .(O.J. Case, etc..victim of crime…)  \nIMPROPER VOIR DIRE  \nIRRELVENT TO CHALLENGES  \n(asking a question which is not related to an intelligent exercise of a preempt or cause challenge)  \nIMPROPER HYPOTHETICAL  \n(asking hypothetical questions that afactually too similar to case)  \nOPENING OBJECTIONS  \nMIS-STATING THE LAW  \n(counsel gives incorrect version of law)  \nARGUMENT in OPENING  \n(opening is making argument on facts)  \nCONSPIRATOR REFERENCES  \n(DA should not reference absent cosuspects, other pleas, other trials)  \nAPPEAL TO EMOTION  \n(irrelevant discussion of pain, loss, or suffering not going to elements)  \nCLOSING OBJECTIONS  \nFACTS NOT IN EVIDENCE  \n(DA cannot argue facts that were not presented at trial)  \nATTACKS ON COUNSEL  \n(improper conduct toward counsel)  \nPERSONAL OPINIONS  \n(counsel giving opinion, “I think…”)  \nPREJUDICIAL/INFLAMMATORY  \n11-403 (DA’s remark prejudice case; Move for Mistrial!)  \nIMPROPER COMMENT ON DEFENDANT’S DEMEANOR  \n(defendant’s general court demeanor not proper basis for comment)  \nIMPROPER EMOTIONAL APPEAL (irrelevant discussion of pain, loss, or suffering)  \nPOLICY ARGUMENT  \n(DA may not argue community values, civil order, or deterrence of crime)  \nBURDEN SHIFTING  \n(refers to evidence not brought by the defendant. Burden is always on state!)  \nIMPROPER 5TH  \nAMENDMENT COMMENT  \n(prosecutor or any state’s witness or makes comment regarding defendant remaining silent) Move for mistrial!  \nBurgess & Porter Law (505) 433-5545 [burgessporterlaw.com](burgessporterlaw.com)","cbCaibwG35q2tnL0","https://ap.wps.com/l/cbCaibwG35q2tnL0","pdf",106599,"English","# Voir Dire Objections\n## Irrelevant; Leading; Lack of Foundation\n## Calls for Speculation; No Personal Knowledge; Ambiguous/Compound\n## Beyond the Scope; Best Evidence; Legal Conclusions\n# Hearsay, Prejudice, and Character-Related Objections\n## Hearsay & Sixth Amendment; Unfair Prejudice; Propensity Evidence\n## Improper Impeachment; Privileged Communications\n## Narrative/Non-Responsive; Unqualified Opinion; Incompetency\n# Opening and Closing Objections\n## Misstating the Law; Argument in Opening\n## Conspirator References; Appeal to Emotion\n## Facts Not in Evidence; Attacks on Counsel; Personal Opinions\n## Improper Emotional Appeal; Policy Argument; Burden Shifting\n## Improper Fifth Amendment Comment; Defendant Demeanor","[{\"question\":\"What are common grounds for objections during voir dire?\",\"answer\":\"Voir dire objections include irrelevant questions, leading questions, lack of foundation, calls for speculation, and questions requiring personal knowledge that has not been established. Objections also cover ambiguous, confusing, or compound questions and questions beyond the scope of direct testimony.\"},{\"question\":\"How are hearsay and Sixth Amendment issues treated in evidentiary objections?\",\"answer\":\"Hearsay objections are raised under evidentiary rules addressing statements offered for the truth of the matter asserted, and they may be tied to Sixth Amendment concerns when the challenged statement is made by someone other than the testifying witness.\"},{\"question\":\"What closing and opening conduct is targeted by objections?\",\"answer\":\"Objections address arguments or statements in opening that misstate the law or improperly make factual arguments. In closing, objections include relying on facts not in evidence, attacking counsel, personal opinions, prejudicial or inflammatory remarks, improper emotional appeals, improper policy arguments, burden shifting, and improper Fifth Amendment commentary about silence.\"}]","Evidentiary Trial Objections - Voir Dire - Opening - Closing Objections Cheat Sheet | PDF"]