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Learn What Motivates Punitive Damages

As a legal category, punitive damages are not very common in U.S. civil trials, being available and awarded in just six percent of cases. But in the broader sense of “punitive,” the motivation to punish or to correct behavior...more

Defense Opening: Give Jurors a Reason for an Open Mind, Not Just a Request for One

For many defense attorneys, there is a routine to the way that they’ll ask jurors to be fair at the start of their opening statement: There are two sides, you haven’t heard the whole story, please keep an open mind. It almost...more

The #When? of #MeToo: Know When Delayed Reports Are Credible

Based on a recent and extensive report from New York’s Attorney General, the state’s Governor, Andrew Cuomo, is now facing numerous credible claims of a pattern of sexual harassment, with his fellow Democrats, including the...more

Expect Another Silver Lining to Online Trials: Shadow Juries Just Got Easier and Safer

The jurors assemble and begin watching the trial — not the actual jurors but the shadow jurors, the ones who are recruited by one side, matched to the real jurors, and offer feedback on the trial as it comes in. They watch...more

The Wrapper and the Contents: Cross Their Expert on Both Levels

One trait of jurors is that, at the start of a case at least, they are not already savvy about the case’s subject matter. So, how do they learn? Through expert testimony. They won’t necessarily just sign-on to an expert’s...more

Once More, Into the Mask: Expect a Post-Pandemic Courtroom to be a Ways Off

It is as if the public health groundhog emerged from its den, saw its shadow, and now promises six more months of confusion, polarization, and pandemic fatigue. With the more-transmissible Delta variant of the Coronavirus...more

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

Embrace Hybrid Trial Preparation

During the past year or so, when clients have scheduled witness meetings or focus group and mock trial research, we will at some point get to the common question: “So, are we doing this in person or online?” Increasingly, it...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

The Post-Pandemic Courtroom: Reflect on When Remote Court Still Makes Sense

The pandemic came upon us pretty quickly, and many of our essential social institutions, including the legal system, had to change just as quickly. The situation called for action, without a lot of time for reflection. Now,...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

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