I believe it is Important to prepare well for jury selection. The focus should be on the critical issues in the case. A brief outline can help remind you of the areas that need to be inquired about. What follows is an outline from an actual trial held in Snohomish County, which resulted in a record damage verdict. The case involved A man and his wife who had immigrated from India twenty years before. They both were dressed in traditional Sikh religious attire, including a religious turban the man wore to court. The case involved a surgery on his heart, which due to a surgical device defect, caused the heart to be seriously damaged and was against the product manufacturer.


  • Attorneys (Names)
  • Our concern about doing good job
  • Three primary interests I want to know  about regarding serving on jury: (1) Personal values (2) past life experiences (3) strong opinions

INTRODUCTION CLIENT (Immigrant & Sikkim Religion

  1. Please look at Mr Singh and his wife
  2. Do YOU personally know anyone who looks like them
  3. Know anyone who wears a turban as part of their religion
  4. They don’t look like any of the rest of us do they?
  5. I suspect there aren’t any members of the Sikh religion here are there? They were born in India and come from a different culture then the rest of us.
  6. Anyone here born in India? Mr. Singh speaks with a heavy accent and is hard to understand. Do you personally know someone whose English is hard to understand?
  7. Jurors have the right to hear and understand the evidence. Will you tell us if you have trouble understanding when he testifies
  8. He and his wife studied and passed the test to become naturalized citizens of the united states. Anyone one here who is a naturalized citizen?
  9. We can agree that he and his wife look different from most of us? That’s a lot of strikes against them isn’t it? How do you feel about that?
  10. When they asked us to represent them in this case IU admit I was worried about my attitudes about the dress, the religion and the fact they were India immigrants. Im not proud of that, but its true. So, I’m wondering if anyone else has a similar reaction I had until I got to know this family.
  • Look: turban, religion, India-culture, accent, naturalized, strikes – my first reaction –
  • international corporations & immigrants from India equal


Some people think a manufacturer selling a medical device should make every reasonable effort to see it is safe and if it finds out there is a defect that can seriously harm it should either fix it or warn about it. Other people, feel its up to the user to discover the defect and avoid the harm. How do you feel about that?

What do you think is the most important priority should be for a corporation making medical devices used in heart surgery regarding its products?

Where would you rank the health and safety of patients in the manufacturer of medical devices used in heart surgeries?

  • rules: how important – why?
  • justice & the rule of law: why following law important?
  • Making product safe important?


It bothers me to talk about money verdicts before you know the facts, but I need to talk about it because the verdict form asks you to determine it. The trial is really all about harm and damages – how much it will take to balance the harm done to Mr. Singh.

One of the questions on the verdict form will be how much money is called for in this case? When figuring it out, some people feel you should consider only the amount of harm. Others think they should consider other things like feeling sorry for plaintiff or that how a verdict might impact them, or the total is too much for one person and other things then simply the harm done.

Responsibility means paying enough money to fully equal the loses and level of the harm and no other considerations. That’s the law. Who thinks they might have trouble keeping things out that don’t belongs there.

Everyone here agrees that in deciding on the verdict size you should figure out the dollar amount based only on the amount of harm and the law as given by the judge. Nothing else.

How much trouble would you have in deciding the dollar verdict based solely on the law and the harm done and nothing else?

Responsibility and accountability mean a verdict fully equal to the harm and loss without considering anything else. That’s the law. Who here thinks they may have trouble doing that?

  • Why talking about this? Because damages only remedy law provides
  • Trial about harm & damages
  • Consider only facts – no sympathy or bias
  • Burden: tip scales – can have doubt
  • Full accountability
  • He doesn’t look hurt
  • Harms list: Each element
  • First personal hospitals experience
  • Economic  damages: Fee bill list
  • Non economic : See harms list
  • In court once -Verdict for past, present & Future


  • How feel about excessive verdicts
  • What makes it excessive
  • What is “Lots of money”
  • Problem being on jury re $25M
  • Any circumstances were $25 Million reasonable?
  • If reasonable & fair – problem signing verdict for $25 Million?
  • Verdict should Fix, help, make up for  as full justice – feelings?


  • Values try to teach children
  • Past experiences that would help you in this case
  • Strong feels about anything you have heard or seen so far?
  • What makes good at job
  • Charities you support


  • Given kind of person, attitudes, life experiences: good juror this case
  • Given same: Any difficulty being juror
  • Anything you would want to know if you were lawyer for this couple suing this company about a juror?


Obviously, this outline would need to be seriously revised and expanded for your case. It is a rough model for a jury selection outline however especially in a case where religion might be an issue.

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