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Witnesses, Remember Confidence is a Behavior

Testifying, whether in a deposition or in trial, can feel pretty threatening. Particularly if you’re a named defendant in a lawsuit, you know you’re going to be the target. But even when you’re on the other side, or you’re an...more

Expect More Extreme Anti-Corporate Attitudes

In modern times at least, corporations have not been terribly popular. However, since the murder of UnitedHealthcare’s CEO about a half a year ago in New York City, observers and the corporations themselves have been paying...more

Keep Doing Your Own Writing

I’m old enough to feel okay claiming full “curmudgeon” status when it comes to A.I. as a writing tool. I know some will say that puts me behind the times, and others will say that I’m missing out on opportunities. But the...more

Follow Five Steps to a Successful Cause Challenge

Cause challenges play an important role in jury selection. When a potential juror has an acknowledged barrier to basing their decision on a neutral understanding of the evidence and the law, they should not serve. However,...more

Account for the Transformation of Your Jurors

Will the individuals who serve on your jury be the same people they were before they were called for service and selected? Will they have the same mental habits and preferences they exhibit in their civilian lives outside the...more

Voir Dire on Attitudes Toward Wealth

America’s civil litigation system can sometimes look a little like class warfare. On one side — often, but not always the defense — there will be an organization and a group of individuals who enjoy substantially more wealth...more

Expect Low Legal Comprehension

These are trying times for those of us who are looking to see whether American rule of law can survive its current challenges. As our executive branch tests the limits of Congressional authority, and bucks the traditions of...more

Witnesses, Build Your Cross- Readiness on Direct

As a witness prepares to testify in trial, the big fear is often cross-examination. While the direct questioning by the witness’s own attorney is seen as the “easy part” (friendly, open-ended questions that allow you to “tell...more

Prioritize Safety for Your Gen-Z Jurors

We live in uncertain times, and that is becoming a more obvious observation by the day. From the turmoil in the financial markets to the tumult in the marketplaces of ideas, there is a widely felt lack of security,...more

Attend to Your Jury

A couple of weeks ago, I was in court to help pick a jury in a high-value case. During that early phase of jury selection, the gallery was full to capacity with potential jurors, the counsel and parties were present, the...more

Help to Protect the Rule of Law

Everyone who works with our court systems, including those who work in civil litigation, are invested in the idea of rule of law. Whether our case has to do with governmental powers or not, whether it involves civil rights or...more

Show (a Little) Facial Expression in Court

It is common advice for witnesses in the courtroom or representatives at counsel table: keep a poker face. That advice — avoid scowls, grimaces, and other head-shaking reactions while you’re being observed by a jury — has...more

Account for a Jury’s Purpose on Damages

Something that we see over and over again in mock trials has now occurred in an actual trial. A recent jury in Allegheny County, Pennsylvania entered a defense verdict in favor of Johnson & Johnson, answering “No” to the...more

Assess Regulator Credibility in Voir Dire

Government regulators can often play a role in civil litigation. In some cases, they’re involved as parties. More often, however, their role is as a proxy. In those situations, jurors might look at whether the defendant...more

Manage ‘Underdog’ Perceptions

There is a case currently playing out in the Southern District of New York, Major League Baseball Players Inc.,v. Underdog Sports, Inc. There is a common dynamic called out right there in the caption: One side is the “Major...more

Know When to Go Easy on Hardship

Early on in the jury selection process, the judge will often ask the panel, “We all know that jury duty can be inconvenient, but who believes they would experience an unreasonable hardship by serving in this case?” Hands will...more

Defendants, Frame Your Alternate Damages as a Test, Not an Admission

Here’s a scenario we often see when watching deliberations in a mock trial: The subject of the defendant’s alternate damages number comes up, and jurors see it as a weakness...more

Account for the New Low in What Jurors Think of Health Insurers

In Charles Dickens’ classic “A Christmas Carol,” the final act is brought by the spectral Ghost of Christmas Future who shows the miserly Ebenezer Scrooge the vision of those he mistreated in life celebrating his death after...more

Expand Voir Dire

Here’s a welcome development: The state of Maryland has embarked on a pilot program to test out the effects of expanded voir dire. In many parts of the country (looking at you, Arizona) the ability of litigants to explore and...more

Don’t Get Lost in Your Own Story

With the 2024 election now in the rearview mirror, many Americans are still processing the results. The Presidential contest between Donald Trump and Kamala Harris was widely seen as close by both pollster and pundit, and...more

Juror Polarization: As the Political Season Ends, Understand It’s Not Just a Season

As I write this, it is finally and mercifully Election Day, 2024. For many of us on the edges of our seats awaiting the returns, we might be considering the question, “What brought us to this?” The answer is that recent...more

11/5/2024  /  Algorithms , Juror , Social Media

Trial Soon? Expect Some Jurors to Have Electoral Stress

I know, I know, there’s a very good chance that every election in your lifetime has been billed as the “most important election in your lifetime.” But when it comes to next week’s election, that hyperbole just might be...more

Be Alert for Conspiracy Thinkers in Jury Selection

As your juror hears testimony from a banking executive, is she thinking that banks are secretly controlling society? As another juror hears from a medical expert, is he thinking that experts like that are the ones who caused...more

10/23/2024  /  Juror , Jury Selection , Trial Preparation

Expect Jurors to Censor Their Opinions

By Dr. Ken Broda-Bahm: With fewer than 30 days to go until one of the most pivotal elections in our history, do you believe the polls?  Many would say “No.” Even when our favored candidate is ahead, we all seem to believe...more

10/10/2024  /  General Elections , Juror

Witnesses, Avoid Absolutes

As they enter a deposition room, or approach the lectern for cross-examination at trial, opposing counsel is looking for an opportunity to make a few memorable points at your witness’s expense. Often that opportunity can be...more

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