Zagnoli McEvoy Foley shares the philosophy that voir dire is the only opportunity to seek information from the decision makers. Good voir dire is a conversation, not cross-examination or indoctrination. Our questions are mostly open-ended and – when possible – designed to be used by both plaintiff and defense counsel.

The questions contained in VoirDireBASE have been used in open court during voir dire. Questions about very private issues should be reserved for in camera inquiry or included in a supplemental juror questionnaire. In some topics this is noted, in others you will need to exercise your own judgment.

Successful voir dire depends on follow-up to get beyond experience into juror attitudes and beliefs; you may use our recommendations for follow-up or supply your own.

The questions are not in any specific order. If the Court limits your time for voir dire, you may need just a few questions that address your case weaknesses so you can quickly identify juror bias. With more time, you may want to explore an entire subject using all of the questions in a category.

Voir dire is as much an art as it is a skill. These questions, written in a variety of ways, allow you to incorporate your own personal style and accommodate the local rules for jury selection in your venue.