Donald Trump has accused the New York judge in his civil fraud trial of "having your own agenda" - and the judge told his lawyer to control his client - as a months-long case that could hobble the former US president's business empire neared its end.
During a contentious final day on Thursday of the trial in Manhattan, Trump once again tangled with Justice Arthur Engoron, who is considering what penalties to impose after earlier finding that Trump's company inflated his net worth to win better financing terms.
"You have your own agenda. I understand that you can't listen for more than one minute," Trump said in court, as he denied wrongdoing and repeated claims of political persecution.
Trump's legal team and the office of New York Attorney-General Letitia James made closing arguments in a case accusing him of inflating his net worth to dupe banks. Kevin Wallace, a lawyer from her office, said Trump's company issued false financial statements every year between 2011 and 2021.
"Fraud was central to the operation of the Trump Organisation's activities," Wallace told the judge.
Trump and Engoron have clashed repeatedly over the course of the trial. Engoron, who earlier on Thursday had faced a security threat at his suburban home, did not appear to be impressed with Trump's argument.
"Please control your client," the judge told Trump's lawyer, Christopher Kise.
Engoron had earlier reacted sceptically to Kise's argument that Trump should not be penalised for allegedly manipulating the value of his properties because lenders and insurers that did business with him still turned a profit.
"There does not have to be any evidence of harm," Engoron said.
Engoron also said he did not find a defence witness to be credible.
James, who brought the case, is seeking nearly $US370 million ($A556 million) and a lifetime ban on Trump from the state's real-estate industry.
Trump is the frontrunner for the Republican nomination to challenge Democratic President Joe Biden in the November election.
Shortly before Trump's legal team concluded its arguments, Alina Habba, another of his lawyers, pointed out that James pledged to scrutinise Trump's business practices while she was campaigning for office as a Democrat. Engoron said that was not relevant to the case.
The trial's closing arguments took place in an atmosphere of heightened security after media outlets reported a bomb threat at Engoron's suburban home. The judge has been a frequent target of Trump's criticism.
Security has been an issue throughout the months-long trial. Engoron's top staffer faced threats after Trump criticised her as politically biased, prompting the judge to issue a gag order barring him from disparaging court staff. Trump has been fined $US15,000 ($A22,500) for twice violating the order.
As James arrived at the courthouse, onlookers cheered and chanted, "Thank you, James." Police stood guard and tightly controlled entrances to the building.
Trump repeated his claims of political persecution and accused Biden, without offering evidence, of orchestrating the lawsuits and criminal cases against him.
"I'm going to go to all of my trials," Trump said at a news conference at one of the buildings he owns.
"This is their new form of cheating." Supporters chanted his name as he left.
Trump has pleaded not guilty in four criminal prosecutions, including two that charge him with unlawfully trying to overturn his 2020 election loss to Biden. All could go to trial before this year's election.
Engoron will issue a verdict at a later date without a jury. He found Trump liable for fraud in September, leaving the trial to focus largely on how much money Trump should surrender as ill-gotten gains.
Trump has appealed Engoron's prior order and is almost certain to appeal any verdict against him, which could delay a final judgment for many months to a year or more.
