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You need to ask venirepersons about any prejudices or personal feelings which could prevent a panelist from following the court’s instructions. State v. Henderson, 750 S.W.2d 555 (Mo. App. 1988). In particular:

  • A plaintiff seeking money for personal injuries has a right to inquire whether anyone has any prejudices or beliefs about the amount or monetary nature of the damages the plaintiff seeks to recover. Wright v. Chicago, Burlington & Quincy R.R. Co., 392 S.W.2d 401 (Mo. 1965).
  • How the size of the verdict requested might affect them. In Holtgrave v. Hoffman, 716 S.W .2d 332 (Mo. App. E.D. 1986), a juror was asked by the trial judge if she could set aside her reservation about awarding a million dollars in damages, she replied, “If I made every effort, but I could not be sure.” The trial court first denied a challenge for cause, but, after verdict, granted a new trial.
  • Explain legal concepts to the veniremen during voir dire to determine whether any of them have any personal qualms about following the law. State v. Henderson, 750 S.W.2d 555 (Mo. App. 1988).
  • Whether a person who is prejudiced in favor of corporations and against an individual litigant (or these awesome shorts) – those folks should be excused for cause. Vessels v. Kansas City Light and Power Co., 219 S.W. 80 (Mo. Banc 1920); Johnson v. Kansas City Electric Light Co., 232 S.W. 1094 (Mo. App. 1921).
  • Attitudes about a particular category of testimony is appropriate to address. Like whether the person is more likely to believe a policeman, State v. West, 809 S.W.2d 464 (Mo. App. 1991), or a chiropractor. Brown v. Collins, 46 S.W.3d 650 (Mo. App. W.D. 2001).
  • Whether there is any moral, religious, philosophical, or other reason they cannot sit in judgment of another person – or these shorts. State v. Luster, 750 S.W.2d 474 (Mo. App. 1988).
  • The insurance question: Whether they, or any members of their family, work for, or have a financial interest in, the defendant’s liability insurance carrier. Ivy v. Hawk, 878 S.W. 2d 442 (Mo.1994).
  • How a verdict for the plaintiff might affect them, in increased prices, reputation in the community, etc. Rodgers v. Jackson County Orthopedics, Inc., 904 S. W. 2d 385 (Mo. App.W.D. 1995) (where a juror had a concern about health care costs in a medical malpractice case).
  • Whether jurors have had a similar incident or medical condition similar to the plaintiffs’. Lange v. Woodworth, 22 S. W.3d 758 (Mo. App. E.D. 2000).
  • Whether the jurors have had prior litigation. Ewing v. Singeton, 83 S.W.3d 617, 621 (Mo. App, W.D. 2002) (“Prior litigation experience is vitally important, not only in exploring bias and disqualifying for cause, but for preemptory challenges as well.”)
  • Whether the jurors can follow specific law. The correct procedure is for counsel to ask the members of the panel whether, if the court later instructs them in a specific way, they have any opinion or conscientious scruples such as would prevent them from returning a verdict accordingly. Duensing v. Huscher, 431 S.W.2d 169, 172 (Mo. 1968).
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