- Be on time for court.
- Make brief objections on
- Stand to object or to address the Court.
- Do not respond to opposing counsel's objection, unless you
first ask leave of the Court to do so or the Court asks you to do
- Do not talk at the same time that opposing counsel, a
witness, or the Court is talking.
- If your client is in custody at the time of trial, bring
appropriate clothes for him to wear to the courtroom, and give them
to the bailiff before the trial.
- Prior to jury selection, the law requires a punishment
election and/or application for probation to be filed ONLY if the
jury is the selection. The Court is automatically the punishment
selection if no election is filed.
- This Court will
announce the time allotted each side for voir dire prior to the
commencement of jury selection.
- Early in the Court's
remarks, the Court will introduce the parties at which time you will
please stand and make an appropriate greeting, e.g., "good
morning" or "good afternoon," etc.
Court expects a challenge for cause to be made when it is reasonably
apparent a challenge is proper. The State should make its
challenges before passing the panel to the Defense. The Defense
should make its challenges before concluding its voir dire. This
Court generally does not permit individual voir dire and expects
challenges to be made in the same manner as any other objection,
i.e., in front of the panel. The Court will explain this process to
the panel. The Court will also inform prospective jurors that they
have the privilege of answering any question privately if they
choose. If you have a prospective juror who is particularly unruly
or out-of-control, you may approach the bench and request individual
voir dire and the Court will consider the request on a case-by-case
basis. The Court will generally consider a challenge for cause
waived if it is not made prior to the jury panel being finally
excused to the hallway for the exercise of peremptory challenges.
In other words, the challenge must generally be made while the
entire panel is present.
- The Court expects each side to instruct their witnesses
that when being questioned by opposing counsel they will directly
answer the questions asked without elaboration unless opposing
counsel asks for elaboration.
- If the Rule has been
invoked, instruct your witnesses accordingly.
- Have your
witnesses in attendance at the court and ready to testify when
- Have your witnesses dress appropriately for
- Do not point firearms, loaded or unloaded, in the direction
of jurors, witnesses, or any other persons in the courtroom.
- If possible, have the court reporter mark exhibits before trial
begins or during breaks.
Post-Trial Communication With Jurors
- Upon discharging a jury, the Court will explain to the
jurors that they may speak with the trial attorneys if they so
choose. Rules of Professional Conduct 3.06(d) forbids a lawyer from
making comments to a juror "calculated merely to harass or
embarrass the juror or to influence his actions in future jury
service." The Court expects nothing less than professional
conduct while talking with discharged jurors. In view of the last
clause, the Court expressly forbids disclosing to the jurors or
discussing with the jurors any information relating to the case that
was not admitted into evidence during the trial. Attorneys may
speak with the jurors in the hallway in front of the courtroom.