In selecting a jury and shaping how a case is presented at trial, it is extremely helpful to know the demographic, attitudinal and experiential characteristics of the actual venire. Voir dire is a highly imperfect tool for obtaining this information, however.

Accordingly, in our experience, where the case budget permits it, trial counsel is wise to have pretrial jury research conducted, not only to enhance counsel’s understanding of the likely venire, but also to assist in identifying, in advance, potential jury biases and prejudices concerning the case.