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Account for a Jury’s Purpose on Damages

Something that we see over and over again in mock trials has now occurred in an actual trial. A recent jury in Allegheny County, Pennsylvania entered a defense verdict in favor of Johnson & Johnson, answering “No” to the...more

Assess Regulator Credibility in Voir Dire

Government regulators can often play a role in civil litigation. In some cases, they’re involved as parties. More often, however, their role is as a proxy. In those situations, jurors might look at whether the defendant...more

Manage ‘Underdog’ Perceptions

There is a case currently playing out in the Southern District of New York, Major League Baseball Players Inc.,v. Underdog Sports, Inc. There is a common dynamic called out right there in the caption: One side is the “Major...more

Know When to Go Easy on Hardship

Early on in the jury selection process, the judge will often ask the panel, “We all know that jury duty can be inconvenient, but who believes they would experience an unreasonable hardship by serving in this case?” Hands will...more

Defendants, Frame Your Alternate Damages as a Test, Not an Admission

Here’s a scenario we often see when watching deliberations in a mock trial: The subject of the defendant’s alternate damages number comes up, and jurors see it as a weakness...more

Account for the New Low in What Jurors Think of Health Insurers

In Charles Dickens’ classic “A Christmas Carol,” the final act is brought by the spectral Ghost of Christmas Future who shows the miserly Ebenezer Scrooge the vision of those he mistreated in life celebrating his death after...more

Expand Voir Dire

Here’s a welcome development: The state of Maryland has embarked on a pilot program to test out the effects of expanded voir dire. In many parts of the country (looking at you, Arizona) the ability of litigants to explore and...more

Don’t Get Lost in Your Own Story

With the 2024 election now in the rearview mirror, many Americans are still processing the results. The Presidential contest between Donald Trump and Kamala Harris was widely seen as close by both pollster and pundit, and...more

Juror Polarization: As the Political Season Ends, Understand It’s Not Just a Season

As I write this, it is finally and mercifully Election Day, 2024. For many of us on the edges of our seats awaiting the returns, we might be considering the question, “What brought us to this?” The answer is that recent...more

11/5/2024  /  Algorithms , Juror , Social Media

Trial Soon? Expect Some Jurors to Have Electoral Stress

I know, I know, there’s a very good chance that every election in your lifetime has been billed as the “most important election in your lifetime.” But when it comes to next week’s election, that hyperbole just might be...more

Be Alert for Conspiracy Thinkers in Jury Selection

As your juror hears testimony from a banking executive, is she thinking that banks are secretly controlling society? As another juror hears from a medical expert, is he thinking that experts like that are the ones who caused...more

10/23/2024  /  Juror , Jury Selection , Trial Preparation

Expect Jurors to Censor Their Opinions

By Dr. Ken Broda-Bahm: With fewer than 30 days to go until one of the most pivotal elections in our history, do you believe the polls?  Many would say “No.” Even when our favored candidate is ahead, we all seem to believe...more

10/10/2024  /  General Elections , Juror

Witnesses, Avoid Absolutes

As they enter a deposition room, or approach the lectern for cross-examination at trial, opposing counsel is looking for an opportunity to make a few memorable points at your witness’s expense. Often that opportunity can be...more

Consider Involving -Both- Sides in the Mock Trial

Mediation is often guided by predictions made by each side, as well as by the mediator: if this case went to trial and faced a jury, what would that jury likely do with it? Naturally, each of these three actors will have a...more

9/18/2024  /  Juror , Mediation , Mock Trials

Witnesses: Be Tough to Cross

Cross-examination is a big deal for a key witness. I’ve noticed in trial that it gets some added attentiveness from the jury. Knowing that they’re now seeing one side pitted directly against the other, jurors will sit forward...more

Avoid Legalese, and Other ‘Magic Spells’

Every trial lawyer I know believes that they are adapting their communication in order to get the jury — or, for that matter, the judge — to understand. At the same time, they will still try to be concise, correct, and...more

When You Concede Liability, Make Sure You Concede With Benefits

Sometimes in civil cases, the plaintiff’s liability claim is opportunistic, wishful, or factually weak. Other times, it is real. Someone didn’t do their job, a danger was missed, or — in that Olympic champion of passive-voice...more

Keep Your ‘Three Hats’ Straight in Witness Prep: Counsellor, Teacher, Coach

When it comes to the delicate task of preparing a witness for deposition or trial, everyone has their own style. It is also true that every witness will have their own needs. Some know the drill already and just need to...more

The Kamala Harris Challenge: Establish (or Reestablish) Your Credibility: Five Lessons

I have long believed that persuaders of all stripes, including courtroom persuaders, can learn a lot of lessons from political communication. The dialogue over the leadership and direction of the country can be a gold mine:...more

8/7/2024  /  Juror , Kamala Harris , Testimony , Witnesses

Don’t Select Your Jury on Gut or Habit: Create a Unique Jury Profile for Every Case

Of all the areas of legal lore, perhaps none are more loaded down with mystique than jury selection. Attorneys with long experience will develop some pretty solid views, and those habits on who they’re looking to seat and who...more

Profile Your Nuclear Juror (Based on the Research)

In addition to making their views known at the ballot box, citizens can similarly broadcast their sentiments in the civil jury box. While they’re asked to merely make a factual finding limited to a specific dispute, the...more

Fight (Constitutionally) for Your Peremptory Strikes

It has become more commonplace to hear talk about a future of litigation without peremptory strikes. After all, Arizona in 2022 was the first state to eliminate strikes in all cases, and it may not be the last. California and...more

Learn from Joe Biden’s Debate Destruction: 5 Nonverbal Don’ts

At last week’s Presidential debate, incumbent Joe Biden performed about as poorly as the worst predictions. In the panicked aftermath, calls have mounted for the 81-year-old President to gracefully exit his party’s nomination...more

Know What You’re Getting with AI Assistance: Your ChatGPT Isn’t “Hallucinating,” It’s Bullshitting

For a little over a year, the world has been abuzz with the experience of accessible artificial intelligence, and overflowing with speculation on the many ways it will change the ways we live and work. For law, a field that...more

Stop Speculating on Your Damages Exposure

As civil jury trials continue to become more scarce, the need to reasonably assess what result a jury would return in trial becomes even more important. Even when the trial does not happen — especially when it does not happen...more

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