Saltzburg, Stephen A., Someone Must Be Lying (2015). 28 Criminal Justice (2015); GWU Law School Public Law Research Paper No. 2015-30; GWU Legal Studies Research Paper No. 2015-30. Available for download at SSRN: http://ssrn.com/abstract=2641149

“There is no rule that governs all cases when determining whether it’s permissible for prosecutors to argue in closing that the jury would have to find that police officers lied in order to find a defendant not guilty. This article examines the issue of the credibility of law enforcement officers in United States v. Ruiz, 710 F.3d 1077 (9th Cir. 2013), United States v. Wilkes, 662 F.3d 524 (9th Cir. 2011), and United States v. Tucker, 641 F.3d 1110 (9th Cir. 2011).”