How have the courts treated the use of inflammatory words at trial?

The parties dispute whether defendants objected to the government's use of inflammatory words at trial. ⁷ Resolving this issue in the defendants' favor, we nonetheless conclude that the district court did not abuse its discretion in failing to grant a mistrial (which was not requested by the defendants) or in sustaining any objection. The district court specifically found that "[t]he opening and closing remarks, while containing an element of righteous indignation, were within the boundaries of proper openings and summations." We agree. The terms "victim," "deceit," "misrepresentation," "falsehoods," "fictitious business entity," "outlandish," "gibberish," and even "charlatan" and "scam," for example, are not even properly characterizable as slang. ⁸ Moreover, the law permits the prosecution considerable latitude to strike "hard blows" based on the evidence and all reasonable inferences therefrom. United States v. Baker, 10 F.3d 1374, 1415 (9th Cir.1993), cert. denied, --- U.S. ----, 115 S.Ct. 330, 130 L.Ed.2d 289 (1994).