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Know How Your Testimony to the Jury Will Differ from Your Deposition

A typical witness preparing for a civil trial often has only one good reference point for what their experience will be, and that is their deposition. That’s where they met opposing counsel, got a taste of that attorney’s...more

Criminal Defendants Taking the Stand: Expect Conventional Wisdom to Change

Recently, three of the most high-profile current defendants did what conventional wisdom says they shouldn’t do; They took the stand in their own defense. Kyle Rittenhouse, on trial for killings at a Kenosha, Wisconsin...more

Opening: Build Your House First, Then Take Aim at Their House

I have worked with more than one defendant who simply could not resist it: Right out of the gate, in opening statement, they come out swinging against the plaintiff. They’re not being honest, they have their own share of...more

Reconsider the Summary Jury Trial

A number of years ago, innovators searching for ways to take some of the pain, delay, and difficulty out of the jury trial hit upon the idea to boil it down, rein in the discovery, simplify the rules of evidence, and try it...more

Expect a Complex Response to Emotional Testimony

Kyle Rittenhouse, the then-minor charged with killing two and wounding a third at a protest in Kenosha Wisconsin in the Summer of 2020, took the stand in his own defense at his trial yesterday. The case is a kind of litmus...more

Account for Camera Perspective Bias

This past Friday, eight people died at a music festival in Houston, crushed by a crowd as the music continued and security was unable to help. As the tragedy moves toward litigation, it is likely that this will be another...more

Use Jurors’ Availability Bias

How likely is it that a corporation’s competitor could come up with a parallel product without infringing a patent? How common is it for someone to get injured on an amusement park ride? How normal would it be for someone who...more

Meet Your Clients on the Cloud

So it is time for your critical meeting with the Client. Are they coming to your office, or are you going to theirs? Or, maybe it is the new option: Let’s just meet on the cloud. An article this past week in the ABA Journal...more

Consider the Connotations

In the case of Kyle Rittenhouse, the individual on trial for killing two men and wounding a third at a Kenosha, Wisconsin protest in August 2020, the judge has set some terms on language. According to press reports, the judge...more

Look at Whether Your Jurors Are Reading: It May Say Something About Their Empathy

Jury duty often involves some long waits. As people sit in the assembly room or the courtroom, it is normal for them to find something to pass the time. I’ve seen people knitting, drawing, even juggling. But, by far, the most...more

Innovate to Keep Track of Information During Voir Dire

The setting of an in-court oral voir dire can be seen as a “perfect storm” of information. Data about your panel and your potential future fact-finders is coming at you from all directions. You may have responses from a...more

Testimony Mode: Note the Tradeoff Between Information Density and Juror Sensitivity

Here’s an intuitive belief that many who work in the field of law might adhere to: More information leads to better decisions. Those who work in the social sciences, however, know that this does not always hold true. Based on...more

(Sometimes) Reinforce a Higher Threshold for Cause Challenges

As you’re waiting your turn for voir dire, you notice that plaintiff’s counsel is getting a fair number of potential jurors to admit that they might have a bias — against lawsuits, against plaintiffs’ attorneys, against...more

Add Context to Your Voir Dire

I came across a recent article in the publication Raw Story with the intriguing title, “There’s a big problem in opinion polling that mainstream media is missing” by Matt Robison. While not an academic piece, the article does...more

Consider the ‘Message Effect’ of Inviting a Consultant to Help Your Witness

Arriving for the preparation meeting, the witness notices that there’s someone new in the room: a communications consultant. A non-lawyer visiting from out-of-town, the consultant is introduced by the lawyer as a specialist...more

Understanding the COVID-Gamblers in Your Jury Pool

Every jury selection involves a variety of issues relating to how potential jurors could feel about the specific case. But there is one issue that is relevant in every current jury selection for an in-person trial: What is...more

Compliment in Order to Persuade

I’ve got to say it: I think I have the best readers in the whole litigation-blogging space. You’re thoughtful, committed, and willing to reach out to me with feedback and ideas for new posts. Honestly, I don’t think I could...more

Gruesome Injury Photos: Consider the Halo of High Impact Evidence

After receiving many warnings from the court and counsel on what they’re about to see, the jurors are finally shown the injury photos. Some of them frown, one covers her face, many look away after a quick glance, and a couple...more

See the Social Roots of Bias

At the voir dire stage of a jury trial, the word “bias” gets used a lot. But do we really know what it means? The courts, in practice at least, hew to a simple meaning: If a potential juror admits to bias, that means they...more

The Civil Jury Trial: Treat the Crisis as an Opportunity

The American civil jury trial was on life support before the pandemic. For a generation at least, the trend has been toward a reduced scope for a jury’s decision, an expansion in the power of judges to resolve things in...more

The Punishment Profile: Know the Situational Triggers

From the time we were kids, most of us swiftly learned what was likely to get us punished: a spanking or — for more recent generations — a time out. Usually, that was brought out by something we did, or by the situation we...more

Courts: Requiring Vaccines Will Influence the Jury Pool. Require Them Anyway

With mounting frustration over the duration and human cost of the Coronavirus pandemic, along with the sluggish pace of vaccinations in many parts of the country, President Joe Biden, this past week, threw down the gauntlet...more

Better Instructions: Make Your Jurors Accountable Devil’s Advocates

Traditionally, we might think about what happens in the jury room as a kind of “Black box,” an unknown process with jurors keeping their secrets on how they got to their verdicts. In practice, however, we know a fair amount...more

Peremptories: Don’t Learn from Arizona

In my last post, I wrote about how the state of Arizona has been a leader in testing options for online trials. That same day, however, Arizona became the first state to eliminate peremptory strikes in criminal and civil...more

Online Trials: Learn from Arizona

Arizona may not be the model when it comes to partisan post-election audits. But when it comes to online or virtual trials, the “Cyber Ninjas” in that context seem to be doing much better. In the Grand Canyon state’s most...more

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