Wu v. Lauria

30 Mass. L. Rptr. 320
CourtMassachusetts Superior Court
DecidedAugust 27, 2012
DocketNo. MICV200804826H
StatusPublished

This text of 30 Mass. L. Rptr. 320 (Wu v. Lauria) is published on Counsel Stack Legal Research, covering Massachusetts Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wu v. Lauria, 30 Mass. L. Rptr. 320 (Mass. Ct. App. 2012).

Opinion

Wilkins, Douglas H., J.

The plaintiff in this motor vehicle accident case, Jolie Wu (“Wu”) has filed the “Plaintiffs Motion for Time Limited (1 Hour Each) Attorney Conducted Voir Dire” (“Motion”). Despite its [321]*321title, the Motion also addresses other aspects of the voir dire process, including a proposed jury questionnaire. The defendant, Anne S. Lauriat (“Lauriat’j has opposed the proposal for attorney-conducted voir dire, but does not appear to oppose the concept of a jury questionnaire or the questions proposed by Wu for live voir dire.

1. Supplemental Juror Questionnaire

By filling out a supplemental juror questionnaire, jurors provisionally seated in the juiy box can provide useful information during what would otherwise be down time while they wait for the selection process to conclude. The Court therefore plans to use a case specific juror questionnaire and to incorporate most of the questions proposed by the plaintiff. The defendant has not proposed additional questions, but may do so no later than the final trial conference on September 4, 2012. At that time, the questionnaire must be finalized to avoid delay on the day of the trial.

To save time, the Court will deploy the questionnaire in the following manner. The Court Officer will give a copy of the questionnaire to each juror at the time he or she is first directed to enter the juiy box. The first 14 qualified prospective jurors will fill out the questionnaire while they wait for the Court to fill in the first 14 seats and to qualify 8 potential replacement jurors (the maximum that the configuration of the Courtroom will allow).1 Once those 22 jurors are in the juiy box or in nearby seats, the Court Officer will collect the completed questionnaires from the first 14 panel members and allow counsel to review them. The 8 replacement jurors will continue to fill out their questionnaires while the attorneys consider and exercise their initial peremptoiy challenges to the 14 panel members in the box. As replacements enter the juiy box to take the place of challenged jurors, they will provide their completed juiy questionnaire to the Court Officer. If additional replacement jurors are needed, they will answer the questionnaires either in writing or at side bar, depending upon which appears most efficient at the time.

The Court anticipates that proceeding in this manner will take only a little extra time and will provide useful information to each side in exercising peremptoiy challenges. Taking that slight additional time is worthwhile to identify potentially biased attitudes and to allow exercise of peremptories based upon something more than stereotypes.

2. Attorney-Led Voir Dire

The question of attorney voir dire is more challenging and controversial. There is, however, no question that the Court has authority to allow it.

Upon motion of either party, the court shall, or the parties or their attorneys may under the direction of the court, examine on oath, a person who is called as a juror therein, to learn whether he is related to either party or has any interest in the case, or has expressed or formed an opinion, or is sensible of any bias or prejudice therein . . .
For the purpose of determining whether a juror stands indifferent in the case, if it appears that, as a result of the impact of considerations which may cause a decision or decisions to be made in whole or in part upon issues extraneous to the case, including but not limited to, community attitudes . . . [and] preconceived opinions toward the credibility of certain classes of persons, the juror may not stand indifferent, the court shall, or the parties may, with the permission and under the direction of the court, examine the juror specifically with respect to such considerations, attitudes, exposure, opinions or any other matters which may, as aforesaid, cause a decision or decisions to be made in whole or in part upon issues extraneous to the issues in the case.

G.L.c. 234, §28 (emphasis added). Typically in Massachusetts, however, the Judge conducts voir dire, not the attorneys. See Toney v. Zaryoff's, Inc., 52 Mass.App.Ct. 554, 557 (2001); Commonwealth v. Burden, 15 Mass.App.Ct. 666, 674 (1983); Julia Mirabella & Geoffrey J. Derrick, “Voir Dire In Massachusetts State And Federal Courts: Commentary And Suggestions For Revision,”2 p. 30 (January 20, 2012) (“Mirabella”).

The plaintiff alleges that there is a widespread and deeply held bias toward plaintiffs in personal injury cases and that attorney-conducted voir dire is the best way to eliminate juror bias. In part, this rests upon the assertion (with anecdotal support) that the public is subject to “a constant barrage of news and information” that “unmeritorious lawsuits are contributing to the country’s economic problems.” Motion at 4. Wu cites Principle 11.B.2 of the American Bar Associations’ “Principles for Juries and Jury Trials,” which states, in part:

Following initial questioning by the court, each party should have the opportunity, under the supervision of the court and subject to reasonable time limits, to question jurors directly, both individually and as a panel.

Most states allow some form of attorney involvement in voir dire, and it is not clear that Massachusetts has the best approach.3 Wu also cites research suggesting that jurors will answer less-frankly to a judge’s questions than to an attorney’s questions because of the judge’s authority and the unwillingness to admit bias to an authority figure.4 Implicit in her argument is the notion that this case, though apparently similar to many other motor vehicle cases on liability, includes claims for damages for an alleged permanent brain injuiy that might suffer from the type of juror bias she fears.

The defendant responds that the Motion “rests on the unproven assumption that prospective jurors are [322]*322more likely to be biased against plaintiffs than defendants.” Sylva v. Anthony, 14 Mass. L. Rptr 337, 2002 WL 202467 (2002) (Gants, J.). In Sylva, Justice Gants reviewed the evidence regarding the success of plaintiffs in certain Massachusetts counties compared to that in other states. For some updated statistics and viewpoints on plaintiffs’ success rates in Massachusetts, see David A. Frank, “Odds Against Tort Plaintiffs in Massachusetts,” Massachusetts Lawyers Weekly (June 14, 2010).5 Justice Gants concluded that “(t]here is nothing to demonstrate that the relatively low success rate of plaintiffs in Massachusetts can be significantly attributed to the absence of attorney voir dire rather than to a host of other possible variables. ” Id. Citing a recent case in which the plaintiff and defendant took the opposite position of their counterparts here, Lauriat argues that limited court-led voir dire would be more beneficial to the plaintiff than the process set forth in her Motion. Actually, that observation tends to support the fairness of the Motion, as the Court would quickly reject any method that favored one side over the other.

The standard practice of this Court and numerous other judges to conduct individual voir dire in nearly all cases, with opportunity for attorney follow up questions directly to jurors, addresses some of the plaintiffs’ concerns.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Commonwealth v. Burden
448 N.E.2d 387 (Massachusetts Appeals Court, 1983)
Toney v. Zarynoff's, Inc.
755 N.E.2d 301 (Massachusetts Appeals Court, 2001)

Cite This Page — Counsel Stack

Bluebook (online)
30 Mass. L. Rptr. 320, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wu-v-lauria-masssuperct-2012.