Pattern Voir Dire Questions: Civil and Criminal

Here are 1,700+ trial-tested voir dire questions, pulled from the author's 20+ years of working with trial lawyers, to help you weed out biased jurors.
Publisher: James Publishing

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2019 Edition
ISBN: 9781949517361
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2019 Edition
ISBN: 9781949517361
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With this 2019 Edition of Pattern Voir Dire Questions, author Christina Marinakis, J.D., Psy.D., brings you new and expanded coverage of key voir dire principles; plus new voir dire questions, strategic advice and practice points throughout the book. The highlights include:


  • (More) reasons to minimize questions aimed at preconditioning
  • Arguing and defending cause challenges
  • Raising and defending against a Batson challenge
  • The Reptile Theory, including:
  • Foundation of the Reptile Theory
  • How it works
  • Practical tips for implementing the Reptile Theory in voir dire (with sample questions for plaintiff)
  • Practical tips for defending against the Reptile Theory in voir dire (with sample questions for the defendant)

New voir dire questions for a broad range of cases and topics, including:

  • Burn injuries and electrocution
  • Products liability: drugs and medical device cases
  • Cyberbullying, threats, online hate speech
  • Attitudes about contracts, generally
  • Attitudes toward risk in business dealings/transactions: buyer beware v. seller be fair
  • Experience with fraud in contract-related business dealings
  • Landlord-tenant disputes
  • Real estate disputes involving loss or damage to property
  • The appropriate penalty – civil or criminal — for moving violations

 An EXPANDED TOPICAL INDEX that includes more than 100 new voir dire questions.

NEW PRACTICE POINTS for implementing/defending against Reptile Theory tactics:

  • Preface a question with “How many of you agree…” when you are trying to show that a belief is universally accepted; preface the question with “Does anyone think…” when attempting to show that a belief is preposterous and unreasonable.
  • [For plaintiff] Be careful not to ask questions that less than half the jury is likely to agree with. Doing so will actually serve to identify your best jurors for the defense to strike. Rather, pay attention to . . . .
  • [For defendant] In closing, you should remind jurors that they agreed to be on the lookout for evidence taken out of context. Then, review all the times the plaintiffs’ lawyers did just that. Pointing out all the plaintiffs’ deceptions drives home the point that plaintiffs’ credibility is highly questionable. It also helps if . . . .

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Table of Contents

Chapter 1 Governing Principles

Civil Cases
Chapter 2 Common Questions – Civil Cases
Chapter 3 Injury Cases
Chapter 4 Business Litigation
Chapter 5 Professional Malpractice
Chapter 6 Employment Discrimination Litigation
Chapter 7 Civil Rights Cases
Chapter 8 Defamation
Chapter 9 Toxic Torts
Chapter 10 Intentional Torts

Criminal Cases
Chapter 11 Common Questions – Criminal Cases
Chapter 12 Crimes of Violence
Chapter 13 Sex-Related Crimes
Chapter 14 Property Crimes
Chapter 15 Motor Vehicle Crimes
Chapter 16 White Collar Crimes
Chapter 17 Drug Crimes
Chapter 18 Domestic Violence

Voir Dire Questions – By Topic