An attorney is licensed and is sworn as an officer of the court. Common law proclaims him to be a "minister of justice in aid of the court." Attorneys are the chief instruments of the Anglo-American system of law. An attorney at a trial is not a contestant like unto a gladiator seeking to prevail at any cost. His cause of action, as well as his opponent's, depends upon a fair and impartially conducted trial. The jury's verdict should be based upon the issues made by the pleadings and evidence, and not upon deceptions created by misconduct.
William L. Libby, Misconduct of the Trial Attorney, 10 Clev.-Marshall L. Rev. 439 (1961)