In a summation in a criminal case, in what circumstances has been described as "excessive personal references" in the summation?

MultiRegion, United States of America

The following excerpt is from U.S. v. Modica, 663 F.2d 1173 (2nd Cir. 1981):

In addition to the instances noted above, the summation was punctuated with excessive use of the personal pronoun "I." More than 60 times in the summation the prosecutor introduced a sentence with "I'm telling you" or "I suggest to you." Occasional use of such rhetorical devices is simply fair argument, United States v. Murphy, 374 F.2d 651, 655 (2d Cir.), cert. denied, 389 U.S. 836, 88 S.Ct. 47, 19 L.Ed.2d 98 (1967), but their constant use runs the risk that the jury may think the issue is whether the prosecutor is truthful, instead of whether his evidence is to be believed. A prosecutor should exercise restraint to avoid needless personal references, without sacrificing the vigor or effectiveness of his argument.

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