Section 21.49 Questions to the Jury

• Library: Criminal Practice 2012 Supp

3. (§21.49) Questions to the Jury

Questions of the jurors should be prepared in advance and tailored to the particular case. Sample sets of questions are provided in §§21.56-21.59 below. Before trial, counsel should consider the types of jurors wanted and the types of jurors not wanted. More attention should be devoted to determining those who are likely to be negative and how to discover or recognize the situation. Counsel should remember that jury selection is a process of elimination!

Inquiry should always be made concerning prior jury service. See United States v. Mutchler, 559 F.2d 955 (5^th Cir. 1977). There is a debate among counsel whether to ask about the actual verdict...