Voir Dire Question Bank

85 voir dire questions organized by phase of questioning and by case type — background and life experience, bias and burden of proof, evidence and expert testimony, deliberation dynamics, plus criminal, civil, and hardship screening sets. Use them as a starting script and adapt each one to your judge, your jurisdiction, and the facts of your case.

Background & Life Experience

Openers that build rapport and surface the experiences most likely to shape how a juror hears your case.

Work and community

Understand daily decision-making, authority, and group dynamics.

  • What kind of work do you do, and how long have you done it?
  • Does your job require you to make decisions that affect other people? Tell me about that.
  • Do you supervise anyone, or does someone supervise your work?
  • What organizations, clubs, or volunteer groups are you active in?
  • How long have you lived in this county, and what brought you here?

Information and media habits

Identify pretrial exposure and how a juror evaluates sources.

  • Where do you usually get your news?
  • Have you read, seen, or heard anything about this case before today?
  • If you have heard something, can you set that aside and decide this case only on the evidence here?
  • Have you discussed anything you heard about this case with family, friends, or coworkers?
  • Do you use social media to follow local news or court cases?

Prior jury and court experience

Surface anchoring from earlier service and expectations about procedure.

  • Have you ever served on a jury before? What kind of case was it?
  • Without telling me the verdict, was the jury able to reach a decision?
  • Was there anything about that experience that would affect your service here?
  • Have you ever been a witness, a party, or a victim in a court case?
  • Have you or a close family member ever worked in law enforcement, the courts, or the legal field?

Bias, Fairness & Burden of Proof

Questions that test whether a juror can apply the legal standard rather than a personal one, and that build a clean record for cause challenges.

Burden of proof and presumption

Confirm the juror accepts who must prove what, and to what level.

  • Do you agree that a party who brings a case has the burden of proving it?
  • Would you want to hear from both sides before deciding, even if the law does not require it?
  • If the party with the burden does not meet it, could you return a verdict against them even if you have questions left unanswered?
  • Does anyone feel that where there's smoke, there's usually fire?
  • Is there anything about the standard of proof the judge described that troubles you?

Attitudes toward the parties and the system

Locate strong priors about institutions, industries, or lawsuits generally.

  • Do you have strong feelings, positive or negative, about lawsuits like this one?
  • Have you or someone close to you had an experience with a situation like the one in this case?
  • Do you believe the legal system usually gets it right? Tell me more.
  • Is there anything about the type of case this is that would make it hard to be fair?
  • If you were a party in this case, would you be comfortable with someone in your frame of mind on the jury?

Building the cause record

Convert a leaning into a clear, preservable statement for the record.

  • You mentioned that you lean one way before hearing evidence — is that a real feeling you'd carry into deliberations?
  • Would it take more evidence than usual to change your mind?
  • Would you say your view is a firm belief rather than something you could set aside?
  • Is that the kind of view you'd want disclosed if you were a party here?
  • Given all that, would it be fair to say this may not be the right case for you?

Evidence, Witnesses & Experts

Questions that reveal how a juror weighs testimony, credibility, and technical proof.

Credibility judgments

Learn what makes a witness believable to this juror.

  • How do you decide whether someone is telling you the truth?
  • Would you give a witness's testimony more weight because of their job or title?
  • Can you accept that honest people sometimes remember the same event differently?
  • If a witness were mistaken about one detail, would you disregard everything else they said?
  • Do you believe someone's demeanor on the stand tells you whether they are truthful?

Expert and technical evidence

Test comfort with competing experts and specialized proof.

  • Have you worked in a field where you relied on scientific or technical reports?
  • If two qualified experts disagree, how would you decide between them?
  • Would knowing that an expert is paid for their time affect how you weigh their opinion?
  • Do you expect scientific evidence in a case like this? What if there isn't any?
  • Is there any type of evidence you would need to see before you could decide?

Direct and circumstantial evidence

Check whether the juror can follow the court's instruction on evidence types.

  • Do you understand that the law treats direct and circumstantial evidence the same way?
  • Would you require an eyewitness before you could find a fact proven?
  • Could you rely on documents and records if no one testified about them from memory?
  • Would the absence of video or photographs make it impossible for you to decide?
  • Can you follow the judge's instructions even if they differ from what you believe the law should be?

Deliberation & Group Dynamics

Questions that predict how a juror will behave in the jury room — often the strongest predictor of outcome.

Leadership and persuasion

Identify likely foreperson candidates and quiet holdouts.

  • When you're in a group that has to decide something, are you usually the one who speaks first?
  • Have you ever been the only person in a group who saw things differently? What did you do?
  • How do you feel about changing your mind after you've stated a position?
  • If most of the jury disagreed with you, how would you handle that?
  • Do you find it stressful when a group can't reach agreement?

Following the process

Confirm the juror will wait for all evidence and apply the instructions.

  • Can you keep an open mind until you've heard all the evidence and the judge's instructions?
  • Can you agree not to discuss the case with anyone, including family, until deliberations?
  • Can you avoid researching the case, the parties, or the lawyers online?
  • Is there anything about the expected length of this trial that would be a hardship?
  • Is there any reason — medical, work, family, or otherwise — you could not give this case your full attention?

Criminal Trials

Focused questions for felony and misdemeanor panels, including police testimony and the defendant's right not to testify.

Law enforcement testimony

Test automatic credit or discredit given to officers.

  • Would you give a police officer's testimony more weight simply because they are an officer?
  • Have you or someone close to you ever had a positive or negative experience with police?
  • Do you believe officers ever make mistakes in reports or investigations?
  • Would you hold it against the State if the investigation had gaps?
  • Can you evaluate an officer's testimony the same way you would any other witness?

Presumption of innocence and silence

Preserve cause challenges on constitutional protections.

  • Right now, before any evidence, is the defendant guilty of anything?
  • The defendant has no obligation to testify or call witnesses. Would you hold silence against them?
  • Would you find yourself wondering what the defendant would have said if they had testified?
  • Could you vote not guilty if the State's proof fell short, even if you suspected something happened?
  • Does the nature of the charge itself make it hard for you to be fair?

Punishment and sentencing views

Identify jurors whose sentencing views affect guilt determinations.

  • Do you have strong feelings about how this type of offense should be punished?
  • Would concern about the consequences to the defendant affect your verdict on the facts?
  • Do you believe certain offenses always deserve the maximum penalty?
  • Could you follow the law even if you disagreed with the possible punishment?
  • Have you or a family member been charged with or convicted of an offense?

Civil & Personal Injury

Damages attitudes, tort reform views, and comfort with awarding money.

Damages and money awards

Find jurors who cannot award noneconomic damages.

  • Do you have any hesitation about awarding money for pain and suffering?
  • Is there an amount of money you believe is simply too much for any injury?
  • Do you believe there are too many lawsuits in this country? Tell me why.
  • Have you ever made or defended an insurance claim? How did it go?
  • If the evidence supported a large award, could you sign a verdict for that amount?

Responsibility and comparative fault

Test personal-responsibility priors and apportionment.

  • Do you believe people should generally accept the risks of everyday life?
  • If both sides were partly at fault, could you assign percentages as the court instructs?
  • Do you think businesses are usually careful about safety?
  • Have you ever been injured and chosen not to bring a claim? Why?
  • Would you require proof of a permanent injury before awarding anything?

Hardship & Qualification

Efficient screening questions to clear the panel of jurors who cannot serve before substantive questioning begins.

Hardship screening

Resolve availability early to protect questioning time.

  • Does anyone have a medical condition that would make sitting through trial difficult?
  • Does anyone care for a child, elder, or dependent who needs you during court hours?
  • Will your employer pay you while you serve? Would missing work create real hardship?
  • Does anyone have travel, surgery, or an exam scheduled during the trial dates?
  • Does anyone have difficulty hearing, seeing, or reading English that we should know about?

Track the answers as you ask

Jury Select lets you record each juror's responses, flag bias, rate the panel, and manage strikes while you question — from a tablet at counsel table or hands-free by voice.