During closing arguments during the guilt phase of appellant’s capital trial, the prosecutor described him as evil and referred to the Bible in calling appellant a disciple of Satan and discussing the apocalypse. The appellate court found no prosecutorial misconduct. Not every reference to the Bible is an appeal to religious authority, and prosecutors may refer to the Bible in closing argument to illustrate a point. Here, a reasonable juror would have understood the biblical references merely as an illustration of the gravity and enormity of the offenses. Since the prosecutor did not use the biblical allusion as an appeal to religious authority, there was no misconduct.
Case Summaries