The jury charge conference is one of the most critical parts of the trial. Every word in the definitions, instructions and questions can influence how the jury responds and must be given careful deliberation. Equally important is navigating the complex process for making tenders and objections to ensure error preservation. With that, here’s how to avoid the most common mistakes on jury charges.
Prioritize and Prepare Early
Prepare the charge early. As trial approaches, trial attorneys are sometimes overwhelmed with getting the case ready. Preparing a comprehensive and well-reasoned jury charge is often put behind other pressing priorities. The better practice is to have a draft of the jury charge prepared early in the case. This will help identify critical elements of the claim or defense, which not only enables targeted discovery but also streamlines the process of preparing the final jury charge in time for the charge conference.
