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Three Key Ingredient to Winning Jury Trials

By Omid Rejali, Esq.

1) Credibility;

2) Logic;

3) Emotion.

These three ingredients will determine whether you will win or lose your jury trial. They will also play a significant role on how much you will be awarded in damages in your San Diego car accident or personal injury case. Let’s break each of them down.


Without credibility there is no chance that you will be able to win a trial. This applies not only to you as the attorney, but also to each of your witnesses including your expert witnesses and of course the plaintiff. No jury is going to want to sit through a trial if they feel you are not being truthful and honest about all of the facts in your case.

This is specifically important when it comes to the bad facts in your case. I will leave the subject of how to deal with bad facts for a different blog, suffice it to day that if you do not discuss your bad facts at the earliest opportunity that you get with the jury (either in mini-openings or during coir dire) chances are that you have already lost the battle of credibility.

Do not under any circumstances shy away from the bad facts. Not disclosing them will only allow the defense to capitalize on it and, that strategy is one that resonates with every jury. You don’t want to sit down after you have given your opening statements, only to have the defense stand up and tell the jury: “well that was a great recitation of the facts from the plaintiff, but let me tell you what he/she did not tell you…” This is a sure way to lose a trial or at least, you will be fighting an uphill battle to try to gain back your credibility from the jury.

Don’t shy away from you bad facts, identify them and discuss them with the jury at the first opportunity that you get.


Logic is a key component in trials because what you are telling the jury must make sense. The logical aspect of things come in mostly from your experts. Depending on the facts and circumstances of the case, you want to make sure that your experts have all of the facts that are important to their opinion ahead of time. You also want to make sure that they are prepared to respond to the defense’s expert and explain why their story does not make sense or how their logic is flawed.


We are all emotional creatures. Some more than others, and in every case you will need to be able to create an emotional connection between your clients case and the jury.

You can do this by explaining to the jury how each character in the litigation from the defense has tried and is continuing to try to prevent your client from getting justice. This of course needs to be part of the theme of your case and needs to start in opening statements and continued through every witness and cross-examination of each of the defense witnesses.

Finally, remember what you are doing-standing up for an injured person who is unable to help themselves and has asked you to help them is an honorable thing. And what the defense attorneys and their team is doing is simply immoral, and unethical. By the time you get to trial, they have had at least 2 years to make it right, and chose not to accept responsibility and come up with excuses, distractions, and blame.

Make sure the jury understands that you and your client did absolutely everything in your power to not have to be there, but the defense left the client with no choice.

Thank you for reading my blog. I hope this helps you.

If you have any other questions, feel free to contact my office at 619-887-4148, send us a text message to 619-485-6313, send me an email at or leave us a message here and we will get back to you.

Born to get you JUSTICE!