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Defense Strategies Jury Trial Bias

Holland & Hart - Your Trial Message

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

Holland & Hart - Your Trial Message

Lawyers and Corporate Defendants – Expect a Little More Hostility from the Jury Box

I suspect there has never been any great love affair between attorneys in general and the jury pool. Jurors know that lawyers are there to influence them toward a desired result, and that’s typically met with suspicion....more

IMS Legal Strategies

What to Include in a Supplemental Juror Questionnaire (SJQ)

IMS Legal Strategies on

Recent years’ events have inspired experiential and attitudinal changes among jurors across the board. The 2016 presidential election and the COVID-19 pandemic fostered a shift in attitudes about corporations, governmental...more

IMS Legal Strategies

Uncovering Juror Bias, Counteracting Nuclear Verdicts, & the Future of Massive Damages – IMS Insights Podcast Episode 47

IMS Legal Strategies on

IMS Strategy Consultant Dr. Clint Townson delves into jurors’ anti-corporate bias—including how to uncover biases through social media research and counteract them with an impactful company story—as well as ways to avoid...more

Holland & Hart - Your Trial Message

Look Beyond Your Jurors’ Political Identification: Education Matters

Whenever we step up to evaluate a person as a potential juror, it can be an occupational hazard to simplify that person too much. We do our best with the time and information available, and to be sure, jury selection would be...more

Holland & Hart - Your Trial Message

Learn from Attitudes Toward Sports Abuse

Many of us probably watched or heard about the drama this past week in the Women’s Olympic Figure Skating event. Kamila Valieva — just 15-years-old, but with a dominant combination of quad-jumps and world class performance...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

Account for Camera Perspective Bias

This past Friday, eight people died at a music festival in Houston, crushed by a crowd as the music continued and security was unable to help. As the tragedy moves toward litigation, it is likely that this will be another...more

Holland & Hart - Your Trial Message

Use Jurors’ Availability Bias

How likely is it that a corporation’s competitor could come up with a parallel product without infringing a patent? How common is it for someone to get injured on an amusement park ride? How normal would it be for someone who...more

Holland & Hart - Your Trial Message

Consider the Connotations

In the case of Kyle Rittenhouse, the individual on trial for killing two men and wounding a third at a Kenosha, Wisconsin protest in August 2020, the judge has set some terms on language. According to press reports, the judge...more

Holland & Hart - Your Trial Message

(Sometimes) Reinforce a Higher Threshold for Cause Challenges

As you’re waiting your turn for voir dire, you notice that plaintiff’s counsel is getting a fair number of potential jurors to admit that they might have a bias — against lawsuits, against plaintiffs’ attorneys, against...more

Holland & Hart - Your Trial Message

Gruesome Injury Photos: Consider the Halo of High Impact Evidence

After receiving many warnings from the court and counsel on what they’re about to see, the jurors are finally shown the injury photos. Some of them frown, one covers her face, many look away after a quick glance, and a couple...more

Holland & Hart - Your Trial Message

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

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

Holland & Hart - Your Trial Message

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

Holland & Hart - Your Trial Message

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

Holland & Hart - Your Trial Message

Stop Asking Potential Jurors About What They Can ‘Set Aside’

At the start of the case, a trial judge somberly addressed the jury, letting them know what adjustments were expected of them. The instructions told them they, “must as jurors, take all the decisions you have made, all the...more

Holland & Hart - Your Trial Message

Note the Progress and the Challenge in Courtroom Attitudes Toward Gay Litigants

As we enter Pride Month, it’s a good time to reflect on where we are. President Biden recently announced a renewed push for full legal equality for LGBTQ individuals, but that takes place against a background of continuing...more

Holland & Hart - Your Trial Message

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

Holland & Hart - Your Trial Message

Juror Questionnaires: Don’t Worry (So Much) About ‘Helping the Other Side’

During the ongoing pandemic, courts have been understandably reluctant to invite large numbers into their chambers for trial, and particularly for jury selection. That situation has driven renewed consideration of...more

Holland & Hart - Your Trial Message

The Punishment Profile: Know the Juror Characteristics

As a defendant thinking about your risk in the run up to civil trial, you probably have some idea of what your case is worth. But you also know, and have likely used, the expression, “Anything is possible with a jury.” There...more

Holland & Hart - Your Trial Message

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

Holland & Hart - Your Trial Message

Watch Out for Self-Sealing Belief Systems

Many Republicans believe that President Trump lost the election only due to widespread and systemic voter fraud. When Georgia’s Republican Secretary of State, Brad Raffensperger, a Trump voter and donor, says that Democrat...more

Faegre Drinker Biddle & Reath LLP

New Jury Selection Procedure in California: Is This the End of Peremptory Challenges? Is This the End of Batson?

Jury selection in California is undergoing significant change. In August 2020, the California legislature passed AB 3070, which was signed by Governor Gavin Newsome on September 30. Beginning in 2022, objections to peremptory...more

Holland & Hart - Your Trial Message

Win and Lose With Dignity

After a tense few days of states counting votes while the public kept refreshing the CNN map, the 2020 Presidential Election has finally been called. And at least in the initial aftermath, we have seen starkly different...more

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