Jury Summons

Jury Summons

Wednesday, February 23, 2022

Jury Instructions: Should Instructions be Improved and Why Good Instructions Matter


            For litigators, years of toil are often capstoned by the trial, and the trial is the final chapter for a litigant’s claims. The lawyers play their role by crafting the best arguments for their clients’ positions, witnesses play theirs by providing facts and context, and judges play their role by ensuring the rules of court are properly followed. But the jury has center stage when it is all said and done and when a decision must ultimately be made. And the last piece of guidance on law and procedure that jurors are given are the jury instructions or the jury charge.

What are Jury Instructions or Charges?

 Jury charges are the questions, instructions, and definitions given to a jury by the judge in a case. They provide direction and information to the jury regarding their deliberations. Often, pattern jury charges are available to help guide attorneys and judges in crafting jury instructions. Pattern jury charges are model jury charges designed to guide judges and lawyers in formulating jury charges.[1] Along with model charge text, they often include comments and references to major cases. The State Bar of Texas produces its own set of model jury charges called Texas Pattern Jury Charges (PJC), which are generally published on a two-year cycle.[2] Other Texas pattern jury charges are produced by private companies.

But, despite these pattern jury charges, research indicates that “[J]urors don’t understand their instructions as well as they think they do, as well as judges, would like to think they do or as well as we in Society might hope they do.”[3]

Why are Jurors Struggling with Jury Charges?

Why are jurors struggling to understand their instructions despite the legal community’s best efforts? Well, for starters, decisions may be rushed in the heat of trial, perceptions too narrowed, or the law too confusing.[4] But other factors contribute to the struggles of jurors as well such as legal language being too complex and the average juror being a legal novice, relatively low average literacy levels, jurors often relying on schemas, stereotypes or shortcuts, and the overall timing of the instructions.[5]

Homing in on the language used in jury instructions, it might be an easy assumption that juries simply don't understand complex legal ideas and so they simply discard them. While it has been found that jurors disregard instructions when they are confused by them, it’s not because they don’t or cannot understand the complex legal ideas.[6] Instead, linguistic complexity is a greater contributor to poor understanding than the actual complexity of the law, and when language is simplified comprehension improves.[7]

Of course, this can have a doubling effect when the fact that a vast majority of jurors are legal novices is taken into consideration. Everyday phrases and language can have a different, significant meaning in law that is lost on jurors, and instructions are too often not written with the novice in mind – leading to more confusion. To overcome this confusion, jurors turn to schemas, stereotypes, and other cognitive shortcuts to make sense of the instructions leading to improper applications of the law and an inconsistent application of the law.

Why Should We Want Better, More Understandable Jury Instructions?

The first and obvious reason why attorneys, judges, and society at large should all want better, more understandable jury charges is the same reason why jury charges matter – the charge is the last piece of guidance on law and procedure that jurors are given. The charge will guide the jurors during deliberations in coming to an ultimate decision.

Of course, all attorneys want jurors to understand their instructions and apply the law correctly to the facts. The same goes for judges. But it might be missed by attorneys and judges in exactly how better jury instructions will help jurors when crafting and giving jurors their instructions. Better written jury instructions have been found to help jurors during their deliberations to effectively discuss facts, evidence, and apply the law correctly to them.[8] Better and more clear instructions also help reduce juror bias, reliance on stereotypes, and overreliance on personal experience or possibly incorrect knowledge of the law.[9] Overall, lawyers and judges have a vested interest in crafting better, more understandable jury charges because better charges will lead to more legally accurate and fairer outcomes.

            Furthermore, proper instructions should be a concern for society as a whole because of society's interest in a fair legal system and the impact the legal system still has on so many. Despite the overall decline in jury trials, a significant number of trials still take place across the country in state and federal courts. An estimated 148,558 jury trials occurred in state courts across the United States in 2007, involving over a million jurors.[10] Poor jury charges or instructions could cause jurors to misunderstand, misapply, or disregard the law. Jury trials still have great impact and often decide the biggest issue in a person’s life. Better instructions will help these jurors make the correct decision in their trial based on a proper application of the law to the facts. Plus, better and more understandable instructions will help juries more consistently apply the law to cases based on the same claims or charges. More understandable instructions will create a fairer legal system and protect citizens' constitutional rights by creating a more consistent legal system.

           Overall, jury instructions are a vital part of the jury system. Instructions are often the last piece of guidance jurors get before beginning their deliberations. Clear instructions can be jurors’ compass or map to reach their decision, but confusing instructions can dismantle much of what trial lawyers have built during the trial. Attorneys, judges, and society will all benefit by taking the time to craft instructions that will guide jurors instead of leaving them lost in the woods.  

              In my next post, I'll dive into techniques that might improve clarity in jury instructions and ways to help jurors better understand their instructions overall.  



[7] Id.

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