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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

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

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

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

Ask Your Doctor If a Jury Is Right for You

We’ve all heard the standard language in drug commercials: After a string of increasingly dire warnings about risks and side effects (a list that seems to nearly always end in “death”), a cheery voice will urge you to, “Ask...more

Expect that Your Jury Is Going to Bring up Those ‘Forbidden Topics’

“We are not supposed to talk about this.” If you’re observing a mock trial, that is often something you hear from one of the mock jurors…just as they begin to talk about it: insurance coverage and attorneys’ fees. Strictly...more

Avoid Persuasive Misalignment

In the case of any argument or persuasive appeal you are making, you can ask the question, “Who are you aiming at?” In a jury trial, your answer might be, “The jury, of course.” But who on that jury are you aiming at in...more

Address the Subjectivity of Pain and Suffering

The damages category of “pain and suffering” is notoriously uncertain, at least in jurors’ estimation. The act of quantifying and monetizing a plaintiff’s subjective experience associated with a loss or an injury can be a...more

Follow Judge Simon’s ‘Casa Le Pyro’

Looking at the question, “What does a federal judge expect from an Assistant United States Attorney (AUSA)?” U.S. District Court Judge Michael H. Simon of the District of Oregon, in a recent issue of the DOJ Journal of...more

Account for One Reason the Polls Are Broken: Social Alienation

We all know by now there were errors in the pre-election polls. While Joe Biden still scored a decisive win, there wasn’t the dramatic margin that many polls predicted. Part of the problem is that the task of sampling the...more

Don’t (Fully) Trust Public Opinion Polls

The 2020 election seems to be nearing the end of the vote-counting phase, with the final ballots in Nevada, Arizona, and Pennsylvania being tallied as I write. But one clear loser is already evident: the preelection polls....more

Comfortably Numb: Account for Desensitization

Recently, I heard about an in-person mock trial during the pandemic conducted by another consultant outside our group. At the beginning of the day, this consultant said, the jurors and the attorneys attending were all pretty...more

Consider COVID Attitude Changes, Part 9: Precaution Is Partisan

President Trump told the Wall Street Journal last week that Americans currently wearing face masks over their mouths and noses might be doing so, not so much to stop the spread of the virus, but to “signal disapproval” of him...more

Appreciate the Advantages of Online Mock Trials

In the past couple of months, I have heard of just a couple of in-person mock trials that have gone forward. They’ve done so with temperature checks, massive social distancing, sometimes masked mock jurors, and generally...more

Use B.A.T.A. to Get Better

The art of training legal advocates has a long and honorable history. For example, the Socratic method used in law school is still an unbeatable way to teach critical thinking. But what about trial advocacy? On that score,...more

Remember, You Can’t Refute a Bias

Imagine that you have in front of you a Bernie Sanders supporter or a Donald Trump supporter. Go ahead and pick whichever one of those is opposite your own political views. Now, convince them that they’re wrong. Assuming that...more

Add Numeracy to Your Jury

Watching a mock jury deliberate about damages can give you the idea that when it comes to numbers, jurors can be a little random. For example, a jury might see a big difference between $500,000 and $1 million in one moment,...more

Interview Your Jurors with Purpose: Eight Ways

The chance to interview a juror is a precious opportunity. Whether it is a mock juror interviewed in the course of a focus group or mock trial, or an actual juror interviewed after they are dismissed at the end of trial, an...more

Choose Your Persuasive Target

When you stand in front of a jury, laying out your opening story or closing your arguments, who are you talking to? “To the jury, of course.” Yes, but which jurors in particular? The conventional wisdom is that you should be...more

Think About Your Case Like an Investor

I spoke with some defense attorneys recently who were surprised to learn of existence of third- party litigation funding groups. These financial companies who will front cash for litigation and trial expenses in hopes of...more

Address the ‘My House, My Responsibility’ Analogy

There is a persistent belief among many mock jurors that I have seen in certain kinds of cases. The belief is that liability attaches automatically to possession, and jurors usually express it through the lens of home...more

Understand Jurors’ Process on Pain and Suffering

Juror 1: “The next category is ‘pain and suffering.’ How are we supposed to get to get that number?” Juror 2: “It is just whatever we want…there’s no guidance for it.“ Juror 1: “How are we supposed to do that? Put a...more

Know that the Law Does Matter in Deliberations (But Not Necessarily Your Version of the Law)

In the real world, disputes are often settled by someone with more or better knowledge, or at least someone claiming to have more or better knowledge. The courtroom, however, is different. It is a setting that is designed to...more

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