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Defense Opening: Repair Credibility First

In an era of increased juror skepticism and perceived “Nuclear Verdicts,” there has been a call for new thinking on defense side. The need is for fresh approaches to cut against the factors motivating jurors toward extreme...more

Encourage Juror Note-Taking (and Take Notes Yourselves)

By Dr. Ken Broda-Bahm: In our increasingly digital world, the idea of taking notes the old-fashioned way with paper and pen can feel quaint. Yet, many of us still do it. For those jurors who are permitted to take notes, they...more

Expect Jurors to Mix Fact and Opinion

By Dr. Ken Broda-Bahm: The distinction between what is fact and what is opinion is arguably one of the most fundamental distinctions in law. But in practice, it is actually a lawyer’s distinction. In the real world, and in...more

Fish for a Good Cause Challenge

In my work, I get to watch many attorneys go through the practical rituals of jury selection. A big part of the job is looking for, setting up, and executing challenges for cause when there are reasons to doubt potential...more

If It Ain’t Broke, and You Fix It, Take Care with What the Jury Learns About It

The adage, “If it ain’t broke, don’t fix it” carries a special meaning in litigation. It can be one of those classic “damned if you do, damned if you don’t” situations: After an injury or other tortious event, if you fix...more

Don’t “Read” Your Jury

A recent issue of American Lawyer included the provocatively titled article, “Why Jury Consultants May Not Be Worth It and Other Tips from Judges.” Reporting on discussions from the Ninth Circuit Judicial Conference, the...more

Call Out Minimized Burdens

At a recent jury selection, opposing counsel — the plaintiff in that case — stepped up to the box of prospective jurors holding two unopened reams of paper. I knew what was coming: If the weight of evidence is completely...more

Wake Them Up: 9 Ways to Make Testimony More Engaging for Jurors

During a recent mock trial, there was one juror seated in the front, gamely struggling to keep her attention on the case. Before too long, however, we saw drooping eyelids, followed by some pretty loud snoring. Admittedly,...more

Voir Dire: Before You Ask ”Can You Be Fair?” Know What You Want the Answer to Be

The court’s purpose in voir dire is to use the time to identify and eliminate those jurors who would have the hardest time giving the case a fair hearing. But layered onto that purpose is the advocate’s goal of working toward...more

Leverage the “Implied Precision Effect” on Damages

I remember a recent mock trial where a jury reached the point of considering damages, and one juror threw out a number to start the discussion: “Let’s just say five million.” When another juror challenged the basis for that,...more

The Trump Juries: Adapt Your Procedures for Higher Profile Jury Selections

In Florida, Georgia, New York, and Washington DC, Donald Trump is facing the looming prospect of jury trials. While the word is overused these days, it is truly unprecedented for a once and maybe-future President to be facing...more

Lawyers and Corporate Defendants – Expect a Little More Hostility from the Jury Box

I suspect there has never been any great love affair between attorneys in general and the jury pool. Jurors know that lawyers are there to influence them toward a desired result, and that’s typically met with suspicion....more

Defendants, Don’t Automatically Avoid the First Move in Settlement

At a national conference I spoke at earlier this week, one of the other presenters was Anne Marie O’Brien of Smith Pauley LLP, a very experienced litigator and mediator working out of Omaha, Nebraska. During her talk, she...more

Model Effective Legal Persuasion

Persuasion is at the core of what litigators do, not exclusively, but particularly in court. Despite that, aspiring lawyers train on a legal model that emphasizes some aspects of persuasion (like evidence and logic) while...more

Trust Your Mock Trial (to a Point)

A mock trial is not a crystal ball with access to the ultimate result you’re going to see in a real trial. There are too many differences between the research situation and the full trial setting for those results to be...more

Witnesses, You’re Preparing for Improv, Not a Play

By Dr. Ken Broda-Bahm: To be clear, testifying isn’t acting. Testifying is telling the truth. And with apologies to those who will point out that good acting is telling the truth as well, there are some important differences...more

Build Trust in Justice

It’s been a season of some firsts: An ex-President, and the leading candidate for a major party nomination, has been criminally indicted (twice so far), and found civilly liable for defamation (once and counting). Rather than...more

Need to Talk About Race in Trial? Watch for Language Polarization

There are a number of scenarios where race might matter to your case. Most obviously in the civil realm, these could be employment cases, police use of force cases, or claims involving unequal medical care or testing. In any...more

Stealing Thunder: Know When to Preempt and When to Wait

When the other side has a powerful potential argument, but you get to go first, then you have a strategic call to make. Do you use the opportunity to get there first, address the issue before they can, and steal their...more

Defend Your Product Testing Regimen: Seven Standards

When you test a product to assess its performance and safety, of course you have very substantive reasons for doing that: You are aiming to check effectiveness, prevent harm, and protect the brand. When a trial occurs,...more

Masks in Court: Understand the Real Lesson

As we begin to take stock of and conduct research on the effects on the pandemic adaptations, it is important to keep an essential principle in mind: The research on pandemic adaptations is not just about the pandemic...more

Experts: Follow the Seven Commandments

I participated in a recent LinkedIn discussion on expert witnesses, with some in the conversation noting that experts are often unprepared for testimony, and often unaware of the need for better preparation. And, to...more

Prepare for Multiple Choice Questions in Deposition

Anecdotally, I have seen it in a few recent cases: The deposition witness isn’t asked an open-ended question and isn’t given a “Yes or No” either. Instead, they are given a range of options, like you would see in an attitude...more

Know the Other Side’s Three Goals for Your Deposition

So, your deposition has been scheduled, and you’re just starting to wrap your head around what is in store for you. Your lawyer has already stressed that you are not in the driver’s seat at this stage: The deposition is the...more

Look Beyond Your Jurors’ Political Identification: Education Matters

Whenever we step up to evaluate a person as a potential juror, it can be an occupational hazard to simplify that person too much. We do our best with the time and information available, and to be sure, jury selection would be...more

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