In March 2026 I spoke to the DuPage County Bar Association about keeping a jury engaged from the first question in voir dire to the last word of closing argument, and this is the substance of that talk for the lawyers who were there and the ones who weren't.
Most jurors have never been inside a courtroom, so what they know about trials comes from TV, and they bring that expectation into the jury box along with a phone they can't check and an attention span trained by everything on it. That's the room you're trying your case to, and the answer is to make the case watchable by giving them a touch of TV lawyering while keeping it grounded in the facts, the evidence and the rules. Hook the jury early and keep the story moving with a case they can follow, because a case jurors can follow is one they can decide for your client.
Jury selection is about the jurors and your client's story, so ask open-ended questions and then step back and let them talk, because the goal is to learn who they really are. When a concept is complicated, explain it with an everyday analogy they'll understand right away.
Three kinds of questions do most of the work. Theme questions surface the jurors' beliefs and connect them to the core of your case, hypothetical questions get them thinking through how they would decide, and experience questions find the life stories that shape their decisions, which is where bias shows up and where real empathy starts.
Rapport comes from how you ask. Look each juror in the eye, one at a time, let them finish their answers, and listen to understand rather than to respond. Match their tone and pace naturally without ever faking it, thank them for honest answers (especially the ones you don't like), and never make anyone sorry they spoke up, because respect earns you influence even when you disagree.
Jurors organize facts through stories, and a story is what gives the evidence meaning, so if your story makes sense, the verdict usually follows. It's your job to organize that story for them, because when it's structured, jurors know exactly what matters and why, and confusion only helps the defense. Use emotion to give the facts meaning so jurors feel the human stakes, and keep the story tight by saying only what moves it forward.
I build every opening around theme, humanity, clarity, emotion and accountability, and then I show it to the jury with visually striking exhibits, short video clips that make a complex point easy to digest, and demonstrations that let jurors see how something happened.
Humanize your client by asking why a juror would care and why they'd want to help, and then find something they can relate to, without crossing the line Illinois draws against asking jurors to put themselves in the plaintiff's place.
Let your experts teach. My test is whether I can explain it to my kids, because if I can, it will land with a jury, so have your experts teach as though the jurors know nothing about the subject, because they don't.
On cross, be surgical and don't get into the weeds with the other side's expert. Show the bias and the inconsistencies, and make the witness explain why the opinion doesn't make sense.
The best damages witnesses are often people with no stake in the outcome, like the co-workers, neighbors and friends who saw the change in your client before and after. And make it interactive by getting witnesses off the stand and into the well to show how something happened, because once you put a spine model or a skull model in a doctor's hands, the medicine stops being abstract.
The jury instructions give jurors a framework, so give it to them by quoting the key instructions directly and putting them on the screen, especially burden of proof and causation, and then showing how each one applies to the facts.
Burden of proof is the one to teach well. Illinois Pattern Jury Instruction 21.01 tells jurors that the party with the burden must persuade them "that the proposition on which he has the burden of proof is more probably true than not true," and a visual of a scale tipped by a feather does more for that sentence than any explanation of it. When the defense case rests on what's possible, the instruction answers it, because anything is possible and the question the jury is actually asked is what's more likely.
If the defense leans on a prior condition, show the jury IPI 30.21, which tells them they "may not deny or limit the plaintiff's right to damages resulting from this occurrence because any injury resulted from an aggravation of a pre-existing condition." Then review the key evidence with images and video that tie the facts to the instructions, and answer the defense arguments with images jurors will remember in the deliberation room.
Early in my career a retired judge told me that if you want to ask for a big verdict, you better put on a show, and I've tried every case since with that advice in mind. The show I mean is structure, clarity and evidence that jurors can see, delivered so they stay with you all the way to the verdict form.
Related reading: A $3.6 Million Will County Verdict in a Crash With No Visible Damage
Related reading: Understanding the Difference Between Discovery Depositions and Evidence Depositions
Related reading: Illinois Appellate Court Permits Discovery Deposition of Deceased Defendant to be Admitted as Evidence at Trial
John D. Risvold is an equity partner at Collins Law Group, P.C. in Naperville, Illinois. He represents individuals and families in catastrophic personal injury and wrongful death cases, focusing on commercial trucking crashes, rideshare and autonomous vehicle litigation, medical malpractice and birth injury, and product defect claims. He has tried cases to verdict in Illinois courts, recovered more than $50 million for clients over thirteen years of practice, and has been named to Best Lawyers in America for Personal Injury Litigation and Illinois Super Lawyers.
This article is for lawyers and is not legal advice.
