Trial counsel should always review the final jury instructions prior to closing. Paragraph B of Louisiana Code of Civil Procedure article 1793 provides: “The court shall inform the parties of its proposed action on the written requests and shall also inform the parties of the instructions it intends to give to the jury at the close of the evidence within a reasonable time prior to their arguments to the jury.” Familiarity with the instructions allows the lawyer to tailor the argument to fit the instructions, by explaining the significance of favorable instructions and explaining why unfavorable instructions should not apply to the particular case.
