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Litigation Strategies Jury Instructions

IMS Legal Strategies

From the Classroom to the Courtroom: Adopting a Juror-Focused Mindset

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Three years of law school can teach us many things. But what they do not do very well—as we typically discover soon after graduating—is prepare us for the actual practice of law. For those of us who always planned to be...more

Proskauer Rose LLP

Latest 'Nuclear Verdict' Underscores Jury-Trial Employer Risk

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Last month, in Jane Doe v. Alkiviades David, a Los Angeles Superior Court jury returned a verdict in a sexual assault and harassment case in the amount of $900 million. This verdict is one of the largest ever for a...more

McManis Faulkner

30 Days Before Trial: It’s All About Teamwork

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Trial is fast approaching. With 30 days left before the starting date, how will you accomplish all the tasks that remain? It’s time to work together and utilize your support staff to get you successfully through the final...more

Troutman Pepper Locke

Correcting the Pattern: Pattern Jury Instructions Can Be Challenged

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As any seasoned trial attorney will tell you, one of the key events during a jury trial is the reading of the jury instructions to the jury. During the reading of the instructions, for a lengthy amount of time, the jury hears...more

Ward and Smith, P.A.

The Third Chair: Engaging Appellate Counsel Early To Improve Outcomes at Trial

Ward and Smith, P.A. on

You don't need us to tell you that trials are increasingly rare. So when heading to trial, trial counsel must know their client's story and must be prepared to tell that story to the trier of fact—a feat that requires...more

Holland & Hart - Your Trial Message

Know Your Jurors’ Anger Buttons

The instructions for jurors are clear: They are to take an issue that has no effect on them, listen dispassionately to the evidence and arguments, apply the facts to the law, and make a decision. That is the model, but in...more

Holland & Hart - Your Trial Message

Be Cautious About Instructing Your Way Out of Bias

Recognizing and reducing bias is obviously essential in a litigation context. But when it comes to “de-biasing,” it helps to see instructions as one tool in the toolbox, but not a tool that’s guaranteed to fix everything. In...more

Holland & Hart - Your Trial Message

Pre-instruct Your Jurors on Hindsight

Jurors are often put in the position of assessing the probability or risk of something at the time a decision was made, before the consequences can be known. “How likely is it that a given result will be the outcome from a...more

Holland & Hart - Your Trial Message

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

Carlton Fields

Taking Charge: Making Specific and Timely Objections to Jury Instructions

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What do you get when you mix a severed finger, a persnickety trial judge, and a global denial of objections to jury charges? Yet another reminder to make timely and specific objections to jury instructions, even when doing so...more

Holland & Hart - Your Trial Message

Appreciate that Your Jurors Need Informal Conversation

A couple of months ago, I helped to run the Online Courtroom Project’s demonstration jury trial using Zoom. Like a number of other experiments and actual trials going forward across the country, jurors showed up via laptop...more

Holland & Hart - Your Trial Message

Face It: Masks Don’t Hinder Credibility Assessment

As a sign of just how serious the coronavirus pandemic is getting, the President has finally appeared in public with a mask. The precaution of wearing a face mask is still highly politicized, but it is slowly catching on. In...more

Carlton Fields

Rejecting Precedent: What Cases About Abortion Rights and the Sixth Amendment Teach Us About Preserving Objections to Existing...

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As the Supreme Court has been debating judicial adherence to the doctrine of stare decisis recently, it bears remembering that litigants seeking a change in the law applicable to their case should make sure to preserve that...more

Knobbe Martens

Time Is of the Essence: Preserve Objections to the Jury Instructions

Knobbe Martens on

HAFCO FOUNDRY AND MACHINE CO. v. GMS MINE REPAIR - Before Newman, Chen, and Stoll. Opinion filed per curiam. Appeal from the Southern District of West Virginia. Summary: Objections to jury instructions should be timely...more

Holland & Hart - Your Trial Message

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

Holland & Hart - Your Trial Message

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

Holland & Hart - Your Trial Message

For Better Comprehension, Let Jurors Read Along During Instructions

Whenever I am running a mock trial and playing the role of the judge, I read the instructions out loud to the mock jurors while they also read along using their own paper copies. I sometimes think that is overkill: If it were...more

Holland & Hart - Your Trial Message

Address Identity and Not Just Belief

Who is a juror? Experienced legal persuaders know a juror isn’t just a passive receptacle for your arguments, and isn’t just an instrument, a route or obstacle to your preferred verdict in the case. Instead, a juror is fully...more

Holland & Hart - Your Trial Message

Don’t Underestimate Just How Much Jurors Want to Reach an Independent Decision

Add this one to the list of reasons why sequestering the jury can be a problem, and more generally, to the “Juries can do strange things” category. The night before deliberations, at the end of a five-week murder trial, four...more

Holland & Hart - Your Trial Message

Instruct the Jury Accurately on Witness Credibility

Given the nature of my involvement in cases, I’m not often present in the courtroom when the jury receives its instructions. But I remember one time that I was. As the judge read out the sections focusing specifically on the...more

White and Williams LLP

Superior Court of Pennsylvania Rejects Pre-Tincher Product Liability Jury Instruction and Grants Tincher Defendant a New Trial

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Despite the monumental change in product liability law brought about by the Pennsylvania Supreme Court’s 2014 decision in Tincher v. Omega Flex, many plaintiff attorneys have continued to push judges to give jury instructions...more

Holland & Hart - Your Trial Message

Turn Your Passive Juror Into an Active Advocate: Seven Ways

Persuading a group that will then go off and deliberate is a unique persuasive setting. In a way, it can be called ‘Second Order’ persuasion, because it isn’t just about the person being convinced in the moment they’re...more

Gray Reed

Some Quick Thoughts on Opening Statements, Closing Arguments and Jury Deliberations

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This will likely be the last piece I write on last month’s trial. We are scheduled to start another trial in January 2018, with additional trials in April and May, and they may gin up some additional insights that I think...more

Carlton Fields

The Key to Jury Instruction Preservation: Objecting with Precision and Completeness

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In Byrd v. Stubbs, 190 So. 3d 26 (Miss. Ct. App. 2016), the Mississippi Court of Appeals reminded us of the need to be diligent during a charge conference by raising specific objections to a proposed jury instruction, as...more

Carlton Fields

When Objecting Once Is Not Enough: Recognizing a Continuing Duty as the Charges and Verdict Form Evolve

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On November 21, 2016, the First Circuit offered practitioners yet another reminder that, as the charges and verdict form evolve through colloquys with the trial judge, there is a continuing obligation to object; the timing of...more

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