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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

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

Ask for a Jury Questionnaire Every Time, Especially Now

In the early preparation for a jury selection, I will often ask the team if there are plans for a supplemental juror questionnaire. Sometimes the answer is that there aren’t any such plans, and they haven’t really thought of...more

Fact-Check the Misinformed, but Remember that Experiences Are as Strong as Facts

Potential jurors arrive at the courtroom with misinformation that might bear on your case. They could have opinions on scientific validity and reliability that will conflict with what your experts will tell them. They might...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

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

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

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

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

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

Address the Causes of ‘Zoom Fatigue’ (and Audience Fatigue Generally)

It has gone from being a surprising observation last spring to a daily truism at this point: Zoom fatigue is real. Now that we are engaged in regular meetings by video web-conferencing, we’ve come to fully grasp the reality...more

Remember that Feelings Trump Facts

In recent days, I’ve been thinking about all of the “QAnon” followers, and how and whether they are reconciling recent events with their belief in Donald Trump’s role in purging the top echelons of politics and society before...more

Break the Backlog: The Durable Conclusions from the Online Courtroom Project

It was just about a year ago that we all started hearing about a novel virus originating in China. A few months later, as American courts ground to a halt, or moved forward haltingly, it started to create the backlog of cases...more

Account for the Optimism Bias

With the coronavirus pandemic infections and deaths once again surging back to peak levels, it is an odd juxtaposition that people seem to be getting out and about at increasing rates. Still, I’ve often heard after someone...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

Guard Against “Expressive Response” in Voir Dire

We know that perceptions of facts can be filtered by a strong partisan lens. Differing narratives regarding the recent election of Joe Biden and Kamala Harris have brought that into sharp relief. While a majority of Americans...more

Allow a Little Awkward Silence

Trial lawyers work in words: language that is precise, economical, and influential. Those words are the water that litigators swim in, and for that reason, the absence of words can be a little uncomfortable. That can be an...more

Confront the Reptile in Jury Selection

The Reptile approach of trying plaintiffs’ cases by framing them in terms of personal safety is no longer a new idea. Plaintiffs’ attorneys are also less likely to treat that approach as a cure-all in every trial. But the...more

Current Attitudes: Account for ‘COVID Clusters’

We are, of course, still in the midst of the pandemic, and if the question is, “How are people feeling about that?” there is not just one answer. There isn’t even a good answer that can be accurately expressed as an average....more

Voir Dire on Content, Not Effect: Lessons from the Tsarnaev Appeal

We tend to think of “bias” as it applies to juries, but courts can have their own deep-seated practices. For example, judges will often prefer voir dire questions that focus on the juror’s own assessment of the influence of a...more

Measure Your Juror’s Faith in the Jury System

As you look out at a panel of potential jurors during voir dire, there are many things you’re likely to wonder about them. Do they have any attitudes toward your client, or people like your client? Are they likely to...more

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