Some simple ideas for voir dire

At a recent trial lawyer’s convention I attended in Boston I wrote down some ideas speakers suggested regarding jury selection. One lawyer from New Mexico gave a great talk about questions which put the jurors in the shoes of your client and help them become involved in the situation so they have personal concern. In defending a client accused of murder when she shot an ex husband who had come into her home at night she asked questions like: : Do you have a plan if someone breaks into your house? Would you shoot an intruder to protect yourself? She recommended having them remember similar experiences in their own lives to give them personal involvement such as: Do you remember the first time you were a patient in a hospital? What frightened you the most about that experience? What was it like? What did the doctor tell you Q. Do you remember the first time you visited someone in a nursing home?

Conservatives who listen to radio talk shows learn to be assertive and argue their positions by listening to the host and callers. In a jury room they can intimidate others. Not only do we need to provide arguments for the jurors on our side, we should try to identify these people by asking questions like: What talk radio programs do you listen to? What talk radio hosts do you admire most?

About Paul Luvera

Plaintiff trial lawyer for 50 years. Past President of the Inner Circle of Advocates & Washington State Trial Lawyers Association. Member American Board of Trial Advocates, American College of Trial Lawyers, International Academy, International Society of Barristers, member of the National Trial Lawyers Hall of Fame & speaker at Spence Trial College
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