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Expect Jurors to Project Themselves into the Situation

A ‘Golden Rule’ argument is one that encourages jurors to put themselves in a party’s shoes and think about what they would or wouldn’t have done. It leads to an objection because it encourages the juror to embrace a personal...more

Make Your Slides Less Texty: Six Tips

In any challenging communication situation, it is best to combine the visual with the verbal. This is good practice because pictures tend to make things more “truthy,” in the sense that claims that are accompanied by relevant...more

Stop Relying on Generational Categories

I often hear questions such as, “Do I want Millennials on my jury?” or “Are Boomers likely to be more conservative on damages?” This focus on the attributes of these generational groupings is part of larger fixation on the...more

Press for Extended Voir Dire (and Don’t Trust Judicial Rehabilitation)

In the context of voir dire, the tension between social science and court practice is becoming close to intolerable. On the court side, we continue under the assumptions that potential jurors are aware of their biases...more

Stop Asking Potential Jurors About What They Can ‘Set Aside’

At the start of the case, a trial judge somberly addressed the jury, letting them know what adjustments were expected of them. The instructions told them they, “must as jurors, take all the decisions you have made, all the...more

Treat Online Trials as an Access-to-Justice Issue

The courtroom is a special place, and there are both symbolic and substantive layers to that special status. At the symbolic layer, there are the physical trappings of the courtroom: dark wood, granite, columns, raised...more

Voir Dire: Create Your Own ‘Candor Script’

As the potential juror sits with the others in the courtroom, the thoughts running through his head might go something like this: “I am being tested on whether I qualify for jury duty…so if that’s what I want, it means giving...more

Speak to Familiarity: Jurors Know What They Like, and Like What They Know

To jurors, most legal cases are unfamiliar by nature. Cases are about the agreement that jurors weren’t a part of, the product they never used, the employer they never worked for. And, more broadly, the cases often rest on...more

Plan for a Hybrid Trial System

There are two theories fighting it out over what will happen once the pandemic fades. The first,  — I’ll call it the “blip theory” — posits that we will simply go back to normal pre-pandemic times, with the lockdown’s...more

Voir Dire: Select on Attitudes, not Race

Juneteenth is now a federal holiday, and even as many would prefer action on voting rights protection, equal access to education and healthcare, and police reform, the symbol is still important. It highlights both the...more

Don’t Oversell Your Limits

Now that the coronavirus vaccinations are moving toward the point of critical mass, it might be safe to think back on the early weeks of the vaccines’ roll-out. At that stage, many health officials were emphasizing the limits...more

Don’t Let Your Virtual Voir Dire Become a Circus

A courtroom process is supposed to be formal and solemn. The habits of delivering justice in person, through decorum and civic ritual, are designed to evoke a deference to the rule of law. When conducted remotely using a...more

Make Your Key Facts Stickier: Five Ways

In complex civil litigation, there’s a lot to manage: a huge wealth of people, events, documents and detail to encourage your fact finders to know and remember. All of them, or nearly all of them, will be important. But some...more

Note the Progress and the Challenge in Courtroom Attitudes Toward Gay Litigants

As we enter Pride Month, it’s a good time to reflect on where we are. President Biden recently announced a renewed push for full legal equality for LGBTQ individuals, but that takes place against a background of continuing...more

Trust the Norming Effect of Deliberations

Critics of the jury system, or simply those who are nervous about taking part, will sometimes characterize a jury’s result as a kind of crap shoot. The feeling is that they’re inconsistent, and subject to the idiosyncrasies...more

Bring Your Jury to the Scene, Virtually

Site visits can sometimes be a part of a criminal case — and predictably, jurors love them as much as school kids love field trips. It can also matter in civil cases, to see where the auto accident or the personal injury took...more

Presenters, Don’t Be Eclipsed By Your Screen

For more than a year, many of us have been presenting to audiences by Zoom or other web-conferencing platforms rather than presenting in person. Largely, the experience has lived up to the challenge, convincing many in the...more

Reduce Resistance, Tell Stories

In legal settings, the emphasis is often on the positive act of giving arguments and evidence for a given outcome: Share the proof and the reasons to believe, and let those appeals work their magic on your audience. But there...more

When You Contradict Someone’s Bias, Don’t Expect a Backfire (But Don’t Expect Easy Persuasion Either)

Wyoming Representative Liz Cheney has just been stripped of her leadership role as the number three Republican in the House. The precipitating incident seems to be that she would not silence her claim that the 2020...more

The Distributed Courtroom: Don’t Assume the Trial Feels Any Less ‘Real’ When It Appears on Screens

With the extended pandemic restrictions and the resulting court backlogs across the country, we have moved tentatively into the world of online trials and hearings, with participants joining from different locations. In that...more

Witnesses, Add to Your ‘Truthiness’ by Showing Pictures

The idea is a merger of pop culture with academics. In pop culture, “truthiness” refers facetiously to the feeling of something being true, independent of its actual truth value (a term coined by late-night comedian, Stephen...more

Direct Examination: Start With a Goal, Not an Outline

A few years ago, I had the opportunity to attend every day of a civil trial, and then interview all of the jurors at the end of their service. I planned out a very comprehensive interview for each of them, including running...more

Ask Your Factfinders to Participate in Their Own Persuasion

To many trial-watchers, a key moment in the recent trial of former Minneapolis police officer, Derek Chauvin, for the murder of George Floyd, came during the testimony of Dr. Martin Tobin. This Chicago pulmonary physician, in...more

‘Not an Anti-Police Trial:’ Dissociate When You Need to

This past Tuesday afternoon, the verdict came in for the most closely watched trial in America right now. The Hennepin County jury found former Minneapolis Police officer Derek Chauvin guilty on all counts in the death of...more

Complete Your Jury-Prep Checklist

In the lead-up to trial, a good trial lawyer has many checklists. Some deal with motions to the court. Some deal with disclosure deadlines, some with witness notifications. In this article, I would like to address the broader...more

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