On this page is a growing library of juror questionnaires, either given or proposed, from actual cases. Use them to brainstorm or cross-check your own voir dire questions; as source material in asking your judge to permit a jury questionnaire; or just as a way to think about how an individual juror's background and experiences might shape the way she hears your case.
Please feel free to submit questionnaires for this page, whether approved by the court or merely proposed, and ask your friends to do the same. If you send one, I'll credit you as author or contributor, and link to your website if you'd like. You can E-mail submissions to me at [email protected]; please tell me a little about the case as well, so I can describe it helpfully. Likewise if you're the author of something I've already posted and would like credit, let me know.
A word about the descriptions below. Nearly all the questionnaires ask for basic biographical information; prior experience with law, law enforcement, juries, and the court system; ability to serve; and knowledge of the case and the witnesses. In describing each questionnaire, I've skipped those topics, and highlighted those specific to the particular questionnaire. It's very possible I missed something of interest to you, so if you think it might be in there, check. Finally, I don't mean to personally recommend any of these questions in your case. I like some of them very much, but this is meant to be a reference library, not a how-to guide.
- United States v. Conrad Black, a 2007 corporate fraud trial in federal court in Chicago. Black was convicted on enough charges that it's fair to say he lost. The questionnaire is 45 pages and touches on business and investing, particular business practices, corporate scandals, Canadians, and people with titles, like Lord Black.
- People v. Kobe Bryant, the 2004 Colorado sexual assault prosecution of the basketball star. The case was dismissed after the accuser decided not to testify. The questionnaire is 13 pages and includes questions on sexual assault, publicity, basketball and basketball players, and sports generally.
- United States v. John Ford, a 2007 corruption trial of a Tennessee state legislator. The defendant was convicted of bribery, acquitted of witness intimidation, and got a hung jury on an extortion charge. The questionnaire is 15 pages.
- State v. Moe Gibbs, the 2007 scheduled North Dakota murder trial of a "former jailer" accused of killing a college student. Gibbs was convicted in November 2007, after an earlier jury deadlocked in the summer. The questionnaire is 34 pages and covers basic topics, very well.
- State v. Dale Hausner, the 2008 Arizona death penalty murder trial of an accused serial killer. As of September 2008, the trial is just getting under way. The questionnaire is 15 pages, thorough on the basics with a death penalty section.
- People v. Michael Jackson, the 2005 California child molestation trial of the pop star. He was acquitted. The questionnaire is only eight pages, but worth looking at. The "have you ever had any training in . . . " queston, for example, is more thorough than many.
- State v. Warren Jeffs, the 2007 Utah sex crimes trial of the leader of a polygamous sect, alleging that he arranged the forced marriage of two young girls. Jeffs was convicted. The questionnaire is 11 pages long and covers publicity and attitudes about the Mormon church. There is an unusually thorough list of questions amounting almost to jury instructions, telling potential jurors what the law is and asking whether they can follow it. Thanks to Arizona trial consultant Dennis Elias for sending this.
- United States v. Lewis Libby, the 2007 federal perjury trial of the Vice President's chief of staff. Libby was convicted. This isn't a questionnaire, but the oral voir dire questions asked by the judge. The list is nine pages. A few of the questions explore beliefs about the foibles of human memory.
- People v. Juan Luna, a 2007 death penalty murder trial of a man accused of a mass shooting at a Brown's Chicken restaurant in Illinois. The defendant was convicted, but a single holdout juror prevented a death sentence. This is the defendant's proposed questionnaire; the newspaper from which I downloaded it added a note saying the final version is sealed. It is 35 pages and includes a section on the death penalty, and more extensive questions than most on jurors' religious and political beliefs.
- Lundberg v. County of Humboldt, a 2005 civil rights action brought by California protestors who said police officers had used cotton swabs to put pepper spray directly into their eyes. The jury found liability but awarded minimal damages. This questionnaire was proposed by the plaintiffs, and I believe was not used. It includes questions about protests and protestors.
- United States v. Donna Moonda, a 2007 federal death penalty murder trial of a Pennsylvania woman accused of hiring her boyfriend to kill her husband. Ms. Moonda was convicted. The questionnaire is 24 pages long and touches on jurors' own recent trauma, mental health issues, witnesses who have made plea bargains, marital infidelity, and the death penalty.
- United States v. Zacarias Moussaoui, the 2006 federal terrorism trial of the accused September 11 conspirator in the Eastern District of Virginia. The questionnaire is 50 pages and very thorough, covering Arabic, airplanes, September 11 and its aftermath, the FBI, mental health training, religious groups and Islam, terrorism, and the death penalty. Thanks to John Gilleland of TrialGraphix for providing this. The government and defense proposed Moussaoui questionnaires are also in this collection; the three versions are used in a voir dire brainstorming exercise in this post here.
- United States v. Jose Padilla, the 2007 federal terrorism trial in the Southern District of Florida. (The case caption is actually United States v. Hassoun, et al.) The defendants were convicted. The questionnaire is 34 pages and explores attitudes toward and knowledge of Arabs; Muslims and the Muslim religion; people from the Middle East; and September 11. Thanks to Margie Fargo of Jury Services Inc. for providing this.
- United States v. Antoin Rezko, the 2008 corruption trial of the man best known as a Barack Obama fundraiser. (The charges were unrelated to Obama.) As of March 2008, the trial is ongoing. The questionnaire is 33 pages long and contains a useful series on political involvement and attitudes toward political fundraising and relationships.
- State v. Gerald Robinson, a 2006 Ohio murder trial of a priest accused of killing a nun 26 years before. The defendant was convicted. The questionnaire is four pages long and very minimal.
- State v. Alfonso Rodriguez, a 2006 death penalty murder trial in North Dakota state court. Mr. Rodriguez was convicted and sentenced to death. The questionnaire is 28 pages and includes questions about the death penalty, mental health and addiction issues, race and ethnicity, and violence and sexual violence.
- Rochester Development, the proposed questionnaire in a commercial civil case in Minnesota in which a real estate development company owned by Arabs sued the architect of a hotel it owned. The proposed questionnaire is 10 pages; the judge used a shorter questionnaire. The case was tried after September 11, so the questionnaire deals with a rare combination of subjects: attitudes toward Arabs and Muslims, and business fraud issues. Thanks to Diane Wiley of the National Jury Project for sending this.
- People v. O.J. Simpson, the 1994 California murder trial of the football star, who was famously acquitted. This isn't an image of the court document; instead it was retyped here at a web site called Vortex.com. Thus I'm less sure of its authenticity, although I have no reason to doubt it. The site says the questionnaire was 75 pages long in its printed form. It includes extensive questions on media coverage, Simpson's celebrity and sports, domestic violence, race and ethnicity, DNA analysis, "expert" (in quotes in the document) testimony generally, and science and math.
- People v. Phil Spector, the 2007 California murder trial of the music producer. The jury deadlocked. The questionnaire is 18 pages long and includes sections on celebrity, publicity, Spector himself and the entertainment industry, firearms, and drugs and alcohol.
- United States v. Cyril Wecht, proposed by the defense in 2006 in the federal corruption prosecution of a Pittsburgh coroner accused of using his office for private gain. The trial started in summer 2007 and as of March 2008 the jury is deliberating. The questionnaire is 26 pages long.
(Photo by Korean Resource Center at http://www.flickr.com/photos/krcla/362137815/; license details there.)
