October 2, 2011 · 3:08 pm

How Well Can You Predict the Outcome of Your Case?

In my years of studying jurors, I have come to find attorneys just as intriguing.  Attorneys know their cases extremely well.  So well, in fact, that it hampers their ability to predict the case outcome, which ironically is precisely the thing that they study the case so intently for.  The objective of taking on any case is to win – whether that means a good sized settlement, a motion to dismiss, a protective order, or a verdict at trial.  Attorneys work countless hours toward that objective, but in becoming so familiar with the case, they become dissociated from the people who are deciding the case and are hearing the facts for the first time.  Things that became important to the attorney over the course of time and which he/she thinks are the cornerstones to the case can be completely irrelevant to listeners, such as mediators, jurors, or judges, who have much less familiarity with the case.  If the purpose is to persuade these listeners, attorneys need to learn to rely on strategies for preparation other than their own intuition.

Attorneys consistently make decisions about their cases based on their own predictions.  They decide whether to mediate, whether to take a settlement or reject it, and whether to proceed to trial all based on their inner predictions.  If attorneys are poor predictors of case outcomes, they may accept low settlement figures or reject adequate offers to settle.  To become better attorneys and better serve clients, attorneys need to become more accurate predictors.  One way of doing so is learning whether previous predictions were correct.  Mock trials can test these predictions as can post-trial juror interviews. 

People as a whole often either over or underestimate their abilities on tasks.  This is not specific to attorneys.  Many attorneys are overly confident in their abilities to predict outcomes.  This is due to many factors.  Attorneys are supposed to be advocates for their clients.  In doing so, attorneys display a confidence about their position.  This confidence can, over time, skew the attorney’s reasoning and make him/her overly confident about the likelihood of success.  It is human nature to become more confident in a goal when expressing confidence to others.  The more one espouses one’s beliefs, the stronger those beliefs become.  Further, attorneys wish for a good outcome.  In wishing for something, they convince themselves that it is true.  This is a strength for zealous advocacy but a weakness when it skews the attorney’s ability to predict and therefore make sound decisions.  Attorneys may also exhibit overconfidence due to a failure to recognize that they are not fully in control of the outcome.   Judges, mediators, and jurors have their own minds.  To the extent that attorneys do not incorporate those individuals’ control over the outcome, they disillusion themselves in making decisions or forming strategies.

A study done by Goodman-Delhunty, Granhag, et. al., tested attorneys’ abilities to predict case outcomes.[1]   Participants consisted of 481 litigating attorneys, the great majority of which were civil litigation attorneys.  The attorneys were asked what a win situation would be in terms of a minimum goal for the outcome of the case.  They were also asked what their degree of certainty was for achieving that minimum goal or better.  In 32% of the cases, the final outcome matched the minimum goal set by attorneys.  In 24% of the cases, the outcomes exceeded the attorneys’ minimum goals.  In by far the majority, 44% of the outcomes were less satisfactory than the minimum goals.  In a large proportion of the cases where the minimum outcomes were not met, the attorneys erred on the side of being over confident.  Further, the higher the confidence level, the more off the attorney’s prediction was from the outcome.  The study also found that experience had no effect on the ability to predict case outcomes: Experienced attorneys were no better at predictions than were inexperienced attorneys.    

If attorneys are so bad at prediction case outcomes, thereby often making poor decisions regarding their handling of the case, how can attorneys do a better job for their clients and themselves?  The answer lies in relying on input from people who are not handling the case.  Attorneys are too ingrained in the case to predict what the decision-makers will do with the evidence.  Focus groups and mock trials give attorneys an opportunity to test their predictions and to see what people distanced from the case find important.  If done before mediation, focus groups and mock trials can direct the attorney as to whether to settle and what range of settlement figures are acceptable for that case based on what jurors would do at trial.  Without the input from outside sources, the majority of attorneys will make decisions which will create an outcome that is less favorable than even their minimum goals. 

[1] Goodman-Delhunty, Granhag, et. al. (2010) Insightful or Wishful: Lawyers’ Ability to Predict Case Outcomes. Psychology, Public Policy, and Law, 16(2), 133-157.\

*This article was originally published in Trial Talk magazine

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September 26, 2011 · 12:16 am

Lessons from the Deliberation Room

When you go through law school, socialize with other attorneys, and draft motions directed to attorneys and judges, you can easily lose the perspective of the rest of the non-legal world. When you go to court and have to convince a jury of lay people, you may overlook some things that come as second nature to you. I came across a blog post by an attorney who was seated on a personal injury trial. Below are some excerpts from his blog along with my commentary. I suggest reading the entire blog post, however, as I will not cover the entire post. The full post can be found at http://mnbenchbar.com/2011/07/role-reversal-a-lawyer%E2%80%99s-jury-service/ 

“Once deliberations started, things got really interesting. My fellow jurors immediately elected me—“the lawyer”—as foreperson.”

Although it is very rare that an attorney, especially a litigation attorney, make it through jury selection, there is a larger point here. Any juror who could be an expert in the topics related to your case are likely to be leaders based on their knowledge. The jury will turn to them to impart advice to the rest of the group. If you believe this juror will see the case in a light favorable to you, then keep him/her on. However, if you are at all skeptical, you should strike them as you never want a leader to be against you.

“I thought it made sense to start our deliberations by trying to separate the plaintiff’s back and neck injuries from her alleged shoulder injury. But several of the jurors wondered why we would use this approach. “The lawyers said her back and neck injuries were not at issue,” one of my fellow jurors said. “To me, that means they’re not part of the trial. We aren’t supposed to award her anything for back and neck injuries…While it was true that the lawyers had said the back and neck injuries were “not at issue,” that was a phrase that I could recall uttering in court, too. When I said it, I meant that both sides agreed on a certain fact or point of law. I did not mean that the fact or point of law was not material to the case.”

Legalese can be very dangerous – even to the point of nixing out entire categories of damages. Realize that when you say things like “not at issue,” jurors have no idea what that means. Make sure that in closing, you follow the format set out by David Ball in his Damages books, wherein you massage the jury instructions, explaining them all in plain English. The danger here is that you may think parts of the instructions are plain English already. Do not assume. Test the instructions in a mock trial or hand them to some younger kids and ask what they think it means. Then apply the plain English instruction to your case. Here, you would have to explain that “not at issue” simply means that it is not argued about. It means both sides agree these injuries exist so you, the jury, do not have to decide that, you accept that they are injuries and your job is to decide how much money it will take to make up for them.

“Jurors were intensely curious about facts that had been hinted at, but not fully developed. For example, there was a single sentence of testimony about the plaintiff’s impressive weight loss since the accident. If she was heavy at the time of the accident, could that have contributed to her shoulder pain? There was no evidence presented at trial to help answer that question, but that didn’t stop the jurors from wondering.”

Often there are small inconsistencies or issues that you don’t spot in your own case because you are too close to it. Focus groups and mock trials help immensely in revealing these issues to you before you step in a courtroom.

“The jurors who had been in car accidents—including myself—saw the collision through that lens. “My accident was worse than hers, and I didn’t get hurt,” one juror said. Interestingly, during voir dire, the judge and lawyers had not asked the potential jurors about their experiences in car accidents in general. They only asked whether jurors had been involved in car accidents where someone was injured. As it turns out, it would have been equally enlightening to hear about the jurors’ experiences in car accidents where no one was injured. After all, a juror who has a car accident where everyone comes away unscathed might be more likely to doubt the alleged injuries of a plaintiff, especially if the juror’s accident was more violent.”

This is evidence of the power of good questioning. Many believe that open-ended questions are anything that does not require a “yes” or “no” answer. Truly open and useful questions, however, do not lead in any sense. Start by asking jurors what experiences they have with car accidents or what comes to mind when they think of a car accident. The less you lead them, the more likely you are to get useful information. Sometimes the most useful answers are answers that your questions would have blocked.

“One eye-opening aspect of deliberations was the importance of the exhibits that were with us in the jury room. I took on the task of going through the medical records one-by-one, reporting to the group any significant information. (Later, another juror double checked me.) More than the live testimony, this process allowed the jury to create a narrative and a time line that helped with deliberations. For example, our review of the medical records confirmed that the plaintiff had not complained of shoulder pain until long after the collision. It also showed that the plaintiff’s existing rotator cuff tear became no bigger as a result of the accident. Also, we saw that the plaintiff was involved in several accidents over the past 15 years, and visited a lot of providers about a host of medical issues—facts that had been mostly suppressed during the trial.

First off, notice that exhibits are powerful and if done correctly, they can be of great use to jurors. Be careful, however, of what your exhibits show. If a bad fact is going to become known through exhibits in the deliberation room, you need to bring up the bad fact yourself during trial. Otherwise, you can be seen as trying to hide something and jurors will hold it against you much more than if you had divulged it. Similarly, many exhibits in today’s world are not even part of the trial. Some of the most powerful exhibits are what jurors find on the internet. In David Ball on Damages 3, there is an appendix that talks about thorough internet searches on topics, parties, and witnesses in your case. If you don’t know what is out there, you can easily lose trial based on facts never brought in the courtroom.

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September 15, 2011 · 2:20 pm

Acts vs. Omissions – A Small But Powerful Difference

You’re creating the story of your case for opening and trial.  You have a situation where a business allowed an unsafe condition to exist on their land and as a result, your client got hurt.  You get to the point in opening where you start to tell the story and you say, “the defendant failed to fix the problem.  They never put up warning signs…”  You may not have realized it, but you have already compromised your story. 

There are two principles to keep in mind when telling a story, whether in opening or questioning witnesses or closing:

1. Acts are more powerful than omissions because jurors forgive omissions much easier than conscious acts or choices.  In focus groups and juror interviews, you consistently hear jurors say “well, it was just an accident” or “anyone could forget that” and so on.  This is because as humans, we understand that no one can think of everything every time, so we let people off the hook for forgetting something.  If the same scenario is framed as a conscious choice, however, it is much harder to forgive because it feels deliberate and intentional.  So, in the above example, you should tell the story as “the defendant sees the pot hole.  He examines it and CHOOSES to walk inside.  He DECIDES to start setting up his shop for business.  Six hours later, the plaintiff comes to shop at the defendant’s store….”  This sets up jurors to see that the defendant knew about the condition and CHOSE to ignore it and do other things that were more profitable instead.  This applies to any type of case:  “the driver chose to drive through the red light” or “the doctor chose to ignore patient safety rules when he did x, y, z.” 

2. The unconscious mind does not know the difference between a positive and a negative and therefore will always interpret something as the positive.  For example, if you say “the driver did not stop for the red light,” the unconscious crosses out the negative and only hears “the driver stopped for the red light.”   Whenever possible, frame your sentences as positives, such as “the driver saw the red light and kept driving.” 

These may seem like small changes, but to the unconscious mind, they make a huge difference.

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September 9, 2011 · 3:49 pm

Proof of the Power of a Story in Opening

Time and again, you have probably been told to “tell a story” during opening.  People remember things best in story format.  But not just any story – it has to be told right.  There can’t be too many details or the story structure gets lost.  Each sentence has to move the story forward in time; otherwise, you’re telling details, not a story.  It must move chronologically (with very few exceptions).  Sometimes it is nice to hear proof of what happens when one side tells a coherent story and the other side does not.  Below are excerpts from post-verdict juror interviews I have recently done on a case.  The plaintiff’s attorney told a story and the defendant did not (or at least not a coherent one that followed the rules of storytelling).  I will remove any names or case information to preserve confidentiality.

Question:  Tell me about the Plaintiff’s opening

Juror 1: I remember initially it seemed kind of goofy because they had already said these people admitted liability and they painted this dramatic picture, which I’m not saying it wasn’t…I understand now why he did it because he was able to give a picture of all the inter muscular damage that was probably done at that particular moment.

Juror 2: It was long.  He went over the details of the case and I was confused because the defendant admitted he was wrong.  It was a case about a man whose life was drastically altered.

Question: Tell me about the Defendant’s opening

Juror 1:  It kind of felt to me like he just didn’t have a story he wanted to tell.  It was more like choppy statements than a story.

Juror 2: I honestly don’t remember specific details of it.  He just tried to paint the picture that none of this was  connected with [the plaintiff’s] problems now.

Notice how neither juror remembers much about the defendant’s opening.  Without a good story, their minds had nothing to grasp hold of.  When you write your opening, make sure the story comes through.  Follow good rules of storytelling and jurors will remember what you say.  They will view the rest of the case through that story lens and shape evidence in their minds to fit with it.  If you do not give them a good solid story on which to base the rest of their evaluations of the case, you lose a lot of leverage.

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September 1, 2011 · 2:49 am

Why Should Jurors Give Money to Your Client?

Jurors are skeptical of giving money to anyone.  It seems like a handout to a stranger.  And worse, jurors do not get to track where the money goes afterward.  There are a lot of factors that go into making jurors want to give your client money, but I want to focus right now on your client’s mental state and demeanor.  Jurors do not want to give to hopeless causes.

Just last week, I ran a focus group on a case with a woman who had severe neck pain following a car wreck.  Liability was admitted.  The plaintiff is on morphine multiple times per day.  But instead of the morphine showing jurors how much pain she is in, jurors focused on “giving money to someone to be doped up her whole life.”  The problem was that the plaintiff did not appear to be doing anything to make her situation better.  She claimed to continue to seek medical attention but could not explain what kind.  She looked through a list of 200 jobs provided by her SSDI attorney but decided she was not able to do any of them.  And to top it off, she’s a smoker.  Jurors immediately figured if she isn’t going to help herself and try to get off the drugs, stop smoking, and try to find a job to take her mind off the pain, they were not willing to give her any money.

It’s human nature.  We all want to help causes that provide hope.  It makes us seem like our money is doing something good and worthwhile.  Make sure your client presents as hopeful.  If they cannot get a job or get out of the house, try to get them to do online surveys for money or look for bookkeeping jobs they can do from home.  Have them seek therapy for the changes they are dealing with as a way to overcome any depression (jurors often fault plaintiffs for not seeking mental health help to cope with depression even if depression is never mentioned).  Get them to read some self-help books instead of watching TV so they can tell the jury about their attempts to better themselves.  See if they can donate their time to a cause that does not affect their pain.  Jurors love to see others trying to help people and put their own pain aside.  Finally, either get your client to stop smoking (pot or cigarettes!) or at the very least not mention it at trial or smoke at the courthouse or outside their homes during the trial.

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August 25, 2011 · 3:13 am

Group Polarization & How It Impacts Your Verdict

Juror deliberations are complicated dynamic processes.  The whole of the group is greater than the sum of its individual parts.  Often people think that deliberations are a series of compromises – and in some ways, they are.  On some issues and in some groups, jurors compromise on damages figures and charges.  But not all of deliberations are compromises.  Sometimes deliberations result in the exact opposite of compromise – a polarizing of attitudes.

Polarization means that jurors who started out with more middle of the road attitudes (just slightly leaning to one side) when put into a group setting become more extreme in their viewpoints.  This means that you can have a group of jurors who individually are fairly open-minded and undecided but who end up extremely opinionated when they enter a room with other jurors and begin discussing the case.

Part of the reason for polarization is that once a juror expresses his/her viewpoint, they are much more wed to that viewpoint in public because there is a stereotype that weak people change their minds and “give in” or admit they were wrong.  No one wants to be weak.  David Ball and his partners have done numerous years of research on jurors and the primitive brain (Reptilian brain).  Their research tells us that the weak member of a group is in danger for their lives.  It is a strong human drive to avoid being seen as weak.  Therefore, jurors may stick to a viewpoint they espoused early on even if they later feel differently.  The result can be a group of jurors who are so split on values that you end up with a hung jury.

One way to prevent this is to explain to jurors how to deliberate.  Groups that start deliberations by discussing their views on the evidence rather than taking polls on verdict questions tend to be much more collaborative and polarization is much less likely.   Suggest to jurors that when they get into the deliberation room, they first and foremost go around the room and discuss their views on the evidence without taking votes.

Polarization also has implications for how you conduct and read into focus group research.  Realize that if you do a non-deliberation type of focus group (or survey research), the results can be misleading when put into a group setting.  Jurors do not decide cases in isolation and the group dynamics make a difference.  That is not to say that those non-deliberation types of research are useless – they certainly have their separate purposes – but do not assume that you know how your deliberations at trial are likely to turn out if you rely solely on individual responses.

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August 18, 2011 · 7:31 pm

Do Jurors Get “Poisoned” During Voir Dire?

Attorneys are often worried about asking questions in voir dire that elicit responses that are harmful to your side of the case.  For example, I hear plaintiffs attorneys worry about asking questions regarding tort reform because they are afraid that jurors will start talking about costs of insurance rising and how lawsuits are chasing doctors out of town.  The fear is that these comments will taint the neutral or good jurors.

My suggestion is not to worry about poisoning jurors on the panel.  Your role in voir dire is to elicit information and you certainly want to hear the bad comments so you can dismiss bad jurors.  Jurors who are favorable to you will not change their opinions simply because a stranger sitting next to them spouts off opposing viewpoints.  If a person holds a fairly well ingrained opinion, they have formed that opinion based on their life experiences.  That opinion has already been challenged by media, friends, and family.  An hour-long voir dire (if you’re lucky to even get the much time) will not change their opinions.  If a juror is neutral on a matter or has not formed any deeply rooted opinions on the topic, they may be swayed by what other jurors say but not to the point of danger to you.  Their opinions will not have been ingrained and they can be easily swayed back to your side during trial.

The most important things to remember during voir dire are:

1. You should listen much more than you talk.  This is a time for you to gather information, not feed jurors facts about your case or try to start convincing them.

2. You need to appear as non-lawyerly as possible.  Jurors hate attorneys and this is your first impression.  Do not under any circumstances argue with a juror about their opinion or try to change it.  You will alienate yourself from the rest of the panel, including your good jurors.

3. Bring out those bad facts and get jurors to commit to their opinions solidly if they are bases for cause challenges.  That will give you a much better chance at removing more of the bad jurors and ending up with neutral or favorable jurors who will then appreciate your openness to different attitudes and trust you more as you begin to present your case.

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August 14, 2011 · 9:14 pm

The Correct Use of PowerPoint & Graphics

As technology as become increasingly prominent in our lives, it has leaked its way into the courtroom.  Some technological advances are extremely helpful when used properly and can be detrimental when used improperly.  So what is the best way to use technology in the courtroom?

Effective Use of Bullet Points. 

  1. Learning Style: There are some attorneys who like to use bullet points throughout opening.  This is not an effective use of a graphic.  Firstly, technology should offer your listeners something extra that you on your own cannot provide.  Simply putting your opening up on a large screen for jurors to read alongside you does nothing to tap into their other methods of processing.  When people are reading something, they are still utilizing the auditory part of their brain, so simply because you have put it in a readable format does not change the brain’s method of processing.  You will still miss the visual learners.
  2. Frequency: Bullet points should be used sparingly.  For example, to list Rule violations of the defendant (which I suggest you do on physical exhibit board that can stay present in the courtroom the entire time rather than through a computer snapshot that disappears when you finish reading).
  3. Timing: Also keep in mind that any time you put something in front of jurors to read, they will be reading as you are talking.  They will tend to read the bullet point, miss what you are saying, and then stop listening as they assume they have all the information they need in that one bullet point.  If you must use a bullet point, put up only one at a time and only put it up after you have finished talking about that point.

Graphics

There is much research to show that people learn better when you access all parts of their brain at one time.  If you can access someone’s  visual part of the brain at the same time that you access their auditory part of the brain, you have a better chance of them remembering and understanding the point.  A good graphic is a picture that is easy to understand without any type of label within the first 3-5 seconds of looking at it.  The graphic should be able to tell a story without any explanation.  Run your exhibits and graphics by mock jurors ahead of time to find out if the graphic tells the story you intend!  Then add a tag line on the top that asks a question that the picture answers, such as “Why Didn’t the Plaintiff See the Hole in the Ground?” along with a photo of how conspicuous the hole is.

Technology can be very helpful – if used correctly.  Do not use it just for the sake of keeping up with the times.  Make sure you are using it to your advantage.

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July 20, 2011 · 3:51 pm

Protect Your Case from Twitter

There has been much talk about the use of blogs for monitoring public opinion and shaping trial strategy during the Casey Anthony trial.  While that may be a useful strategy for high profile cases, you may wonder what impact the internet will have in your everyday run of the mill case.  It has a very real impact, just in a different way.

The dangers of the internet are becoming so pervasive that it is now imperative that you understand the importance of doing internet research.  Jurors are internet-savvy (even some of the older ones) and you can almost guarantee that at least one of your jurors will be going home researching every aspect of your case online.

If that one juror finds something harmful to your case, they will bring it up in deliberations and impact the rest of the jurors. 

Jurors will research you, your firm, your experts, your client, and even medical terms or other issues related to your case.  They will go on facebook, myspace, google, twitter, etc.  They will research arguments in your case – whether a 5mph collision can cause brain damage.  Whether brain damage can occur  without a concussion.  Whether there really is a policy that doctors have to do a differential diagnosis and rule out the most dangerous possibility first.  Guaranteed, they will find articles and websites that dispute your claims and because the juror found them online, they think the sources are neutral and therefore more trustworthy than your experts.

What they find on their own online will trump your evidence. 

So what do you do about it?  You need to know what is out there.  You cannot undermine what you do not know.   Either hire someone skilled at internet research or find someone in your office who is young and can dig deep on search engines.  That person needs to set aside multiple hours to research every aspect of your case and every person involved.  You need to know what is out there so that you can mention it during trial.  Know what arguments there are against you and have your experts explain the faults in those arguments so that when jurors come across it, they know why not to believe it.  These days, you can lose a case because of jurors doing due diligence to research on their own.  Your loss may have nothing to do with what goes on in the courtroom.  Recognize this danger and devote time and effort to online research – even before accepting a case.  The costs of avoiding it may be high.

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July 14, 2011 · 2:46 am

Should Your Client be in the Courtroom?

There are many cases on which I consult where the question arises, do you bring the client to the courtroom?  This is often an issue in brain injury cases and in cases of severe physical impairment, but it can be an issue in any case, such as soft tissue injuries.

The concern is that jurors will do one of two things:

  1. Either they will devalue the plaintiff’s injuries if the plaintiff looks and acts normal (or doesn’t seem to be in much pain), or
  2. They will see terrible injuries but view the client’s presence as a ploy to invoke sympathy.

Consider in addition to the above issues that if your client has horrendous injuries, the longer the jury looks at them, the more accustomed to them they become and the less disturbed they will be.

The problem with not presenting the plaintiff, however, is that jurors may hold it against you and if the plaintiff does have visible injuries (or severe enough mental injuries), you lose the chance to show jurors the extent of the damage.  The best way to know whether presenting the plaintiff will do more harm than good is to test the plaintiff’s presence in a focus group or mock trial (usually by video so as to preserve confidentiality).

Focus groups aside, however, why not ask your actual jurors during voir dire which they would prefer?  Tell jurors that you need to make a decision and you’re going to look to them for guidance. And then be honest.  Tell them about your client and the extent of
injuries.  Then explain that some jurors would require the plaintiff to be at trial so that you could at least see him/her and so that he/she is part of the process.  Others say that it’s unnecessary for the plaintiff to be here and that if you did bring him/her here, they would get the feeling that you were trying to play on their sympathy (which you tell them earlier on and throughout voir dire that you are not going to do).  Tell them that you are concerned that if you do bring him/her in, some jurors will say that you were trying to invoke sympathy and yet if you don’t bring him/her in, you’re afraid that some jurors will say you should have brought him/her here and will hold it against you and the plaintiff.  Ask them for help on that decision.  This will take the burden off of you and regardless of what you choose (you may have jurors disagreeing), you have put yourself off-code from being a typical lawyer
and they will understand that different jurors told you different answers.

In cases where your client is severely injured, the best solution is often to have the client present for voir dire and to testify, but quickly get them out of the courtroom at all other times.  This way, the jurors get to see and evaluate your client and yet do not have time to get accustomed to the injuries.  In such cases, it is easy to explain to jurors that your client is either in too much pain to stay in court all day and/or that his/her doctors have said that it would be mentally to difficult to hear all the testimony.

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