Defence lawyers in the Colorado cinema shooting trial are trying hard to keep jurors from knowing the worst details of the massacre, fighting to prevent survivors from revealing how badly they were injured and objecting to photos showing even small amounts of blood.
Their persistent efforts frustrated the judge who told them: "The defendant has a constitutional right to a fair trial. The defendant doesn't have a constitutional right to a sanitised trial."
Holmes killed 12 people and injured 70 others during a packed midnight premiere of a Batman movie, but has pleaded not guilty by reason of insanity.
James Holmes' defence want to keep the trial focused on whether he was legally insane, not the nightmare of the attack, concerned that the gory details could sway jurors.
"This is a particularly difficult case for that sort of argument," said Denver defence lawyer Scott Robinson, who is not involved in the Holmes case. "It's not humanly possible to separate gruesomeness from the theatre shooting trial.
"With so many shots fired, so many people shot, so many lurid memories recounted by so many witnesses, the jury will be revolted. They've already hated what they've seen, and it's not even close to over."
In the three weeks since the trial opened, dozens of witnesses and police officers have offered harrowing details of their experiences in the cinema. on that night in July 2012
"The upsetting thing is that the defendant went into a theatre of innocent people and shot," prosecutor Rich Orman told the judge. "The upsetting thing is the defendant shot a little girl."
Jurors will see still more crime scene photos when the trial resumes today.