VOIR DIRE
Good morning, ladies and gentlemen. I am Judge Andrews. We are going to select a
jury in a criminal case called _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
I am going to ask you a series of questions to help the Court and the attorneys in the jury
selection process. Before I ask any questions, I am going to ask the Deputy Clerk to swear the
jury panel to answer any questions truthfully. (To Deputy, Please swear the panel).
If any ofyou answer "yes" to any ofthe questions that I ask, please raise your hand, and,
when recognized by me, please stand, state your name and your jury number. At the end of the
questions, the Deputy Clerk will ask some of you to take seats in the jury box, and, after that, the
lawyers and I may ask those of you who answered "yes" to one or more questions to come up to
the bench to discuss your answers with the lawyers and me.
The presentation of evidence in this case is expected to take _ _ days, but jury
deliberations could extend your service beyond that. The schedule that I expect to keep over the
days of evidence presentation will include a morning break of fifteen minutes, a lunch break of
an hour, and an afternoon break of fifteen minutes. We will start at 9:30a.m. and finish no later
than 5 p.m. each day.
1. Does the schedule that I have just mentioned present a special problem to any of you?
2. (Description of the case). This is a criminal case involving charges of
_ _ _ _ _ _ _ _ . The jury in this case will be asked to decide whether the defendant is
guilty beyond a reasonable doubt of the charges against him/her.
2A. Have any of you heard or read anything about this case?
2B. Is there anything about the nature of the charges that would prevent you from being a
fair and impartial juror?
3. The lawyers and law firms involved in this case are: (typed list to be supplied by the
parties). Do any of you or your immediate families, such as spouse, child, parent, or sibling,
know any of the attorneys or law firms I have just named?
4. Have any of you or your immediate families had any business dealings with, or been
employed by, any of these attorneys or law firms?
5. The potential witnesses in this case are: (typed list to be supplied by the parties). Are
you familiar with any of these potential witnesses?
6. The law enforcement agencies involved in this case are
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Would the fact that investigated this case interfere with your ability
to be fair and impartial?
7. Have you or any member of your immediate family ever been employed by, or
investigated by, any law enforcement agency, including ?
8. Do you believe that you will give more or less weight to the testimony of a law
enforcement officer, simply because he or she is employed as a law enforcement officer?
9. Have you or any member of your immediate family ever been (a) a victim of a crime,
(b) a witness in a criminal case, or (c) arrested for a crime, not including minor traffic offenses?
10. Do you have any opinions about the criminal justice system that might make it
difficult for you to be a fair and impartial juror in this case?
11. If you are selected to sit as a juror in this case, are you aware of any reason why you
would be unable to render a verdict based solely on the evidence presented at trial?
12. If you are selected to sit as a juror in this case, are you aware of any reason why you
would not be able to follow the law as I give it to you?
13. A fundamental principle of our legal system is that when a person is charged with a
crime, [s]he is presumed to be innocent unless and until the Government proves guilt beyond a
reasonable doubt. If you are selected as to sit as a juror in this case, will you have difficulty
following this rule of law?
14. , as the defendant in this case, may choose not to testify in his/her
own defense, and I instruct you that the choice not to testify, if that is choice, may not
be held against . If you are selected as a juror in this case, will you have
difficulty following this instruction?
15. Testimony may be presented in this case by a witness who has agreed to testify as
part of a guilty plea agreement with the Government. I instruct you that if such a witness
testifies, you will have to evaluate that witness's testimony as you would that of any other
witness. If you are selected as a juror in this case, will you have difficulty following this
instruction?
16. Have you served on a jury in a criminal case before?
17. Have you served on a grand jury before?
18. Is there anything, such as poor vision, difficulty hearing, difficulty understanding
spoken or written English, that would make it difficult for you to serve on this jury?
19. This is the last question. Is there anything else, including something you have
remembered in connection with one of the earlier questions, that you think you would like to tell
me in connection with your service as a juror in this case?
