Back at the Libby trial. This morning, prosecutor Patrick Fitzgerald has accused the Libby defense of employing a strategy of jury nullification. In arguments outside the presence of the jury, Fitzgerald said that Libby’s so-called “scapegoat” defense — the argument that Libby is the only person charged in a case where other people engaged in possible wrongdoing — is, in Fitzgerald’s words, “a blatant appeal for jury nullification.” Libby defense lawyer Ted Wells shot back, “Mr. Fitzgerald has this nullification thing on his mind so much he’s starting to imagine things.” A short time later, Fitzgerald used the term again, saying this time that Libby’s attempt to show that he might have heard about Valerie Plame Wilson from Washington Post reporter Bob Woodward was an “attempt at jury nullification.”