Of all jury trial proceedings, voir dire is routinely the most anxiety-inducing and least well done. While even the most experienced trial attorneys manifest little apprehension with opening statements, cross examination of difficult witnesses and experts, or closing arguments, the thought of actually having to talk with prospective jurors—like a real and invested human being, for an extended period of time—can be almost terrifying for some.

We can debate why this is, but surmise it reflects the attorney’s inability to control the situation or predict the often–surprising answers they will get to questions from people they don’t know. Nonetheless, there are methods to reduce the fear associated with voir dire, and techniques useful to conducting a proper examination that will allow counsel to exercise proper challenges for cause while reserving peremptory challenges for uncertain cases.

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