• videocam Live Webinar with Live Q&A
  • calendar_month September 24, 2026 @ 1:00 PM ET/10:00 AM PT
  • signal_cellular_alt Intermediate
  • card_travel Personal Injury and Med Mal
  • schedule 90 minutes

Maximizing For-Cause Jury Strikes in Civil Cases: Techniques and Practical Tips

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About the Course

Introduction

This CLE webinar will offer techniques and practical tips to trial attorneys for challenging a potential juror for cause, how to prevent opposing counsel from rehabilitating that juror, dealing with judicial rehabilitation efforts, and preserving objections to the court's denial of a cause challenge. The panel will discuss the difficulty of defining impartiality and changing attitudes on the use of peremptory challenges.

Description

When picking a federal civil jury, each party is only allowed three peremptory strikes unless the court allows more. Some states have significantly abridged peremptory strikes. Although there is no limit to the number of prospective jurors who can be challenged for cause, the court decides whether cause has been established, and the court may question jurors in an effort to rehabilitate them. A number of states have legislated that certain listed opinions or attitudes are insufficient cause for challenge.

Trial attorneys need to understand what would render a potential juror impartial and then get the juror to express those issues in a way that convinces the court. If the request to challenge for cause is denied, any objections to that request have to be preserved and appealed if the case is lost. 

Counsel need dependable techniques and strategies for identifying the attitudes or issues that could spell trouble in a given case, have ways of getting each juror to open up about them, and then make sure that the "cause" for challenge is patently clear to the court. The flip side of challenges for cause is rehabilitation, so both plaintiff and defense counsel will be trying to conduct voir dire in a way that makes rehabilitation of the other side's "favored" jurors more difficult.  

Listen as this panel of eminently qualified speakers offers guidance on successfully challenging a potential juror for cause, anticipating and navigating rehabilitation attempts, and preserving objections to the court's denial of a cause challenge.

Presented By

Jorge Monroy, M.A.
Senior Jury Consultant
Verdict Insight Partners

Mr. Monroy partners with trial teams to design and execute jury research that informs case strategy and supports effective decision making. He specializes in advanced statistical and quantitative methods, drawing on data from jury research, community attitude surveys, and jury selections to help counsel assess risk, refine themes, and anticipate juror reactions. Mr. Monroy also works closely with trial teams on juror questionnaires, voir dire strategy, and the development and refinement of opening statements and key case narratives.

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Tyler M. Paetkau
Owner
Paetkau Law Group

A California-based litigator, Mr. Paetkau has represented employers in labor and employment law matters for over 30 years. As both a trusted advisor and litigator, he has handled a variety of labor and employment challenges, including claims of wrongful termination, discrimination, retaliation, sexual harassment, defamation, wage and hour violations, unpaid commissions, collective and class actions, and unfair labor practice charges. Mr. Paetkau also represents employers in litigation involving unfair competition, misappropriation of trade secrets, restrictive covenants, and employee mobility issues. He also has extensive experience representing employers in traditional union-management labor relations matters, including union organizing campaigns, strikes, and collective bargaining negotiations. Mr. Paetkau  also specializes in international labor and employment law issues and is active in the ABA’s International Labor and Employment Law Committee. He is a frequent writer and speaker on employment law issues. 

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Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.


  • Live Online


    On Demand

Date + Time

  • event

    Thursday, September 24, 2026

  • schedule

    1:00 PM ET/10:00 AM PT

I. Relevant law

A. Federal Rule 47 and 28 U.S.C. §1870

B. Continued authority of Batson v. Kentucky and criticism of peremptory strikes

II. Impartiality and the reality of what counsel seek in a juror

III. Identifying the key issues that might prevent a juror from applying the evidence and the law

IV. Developing questions to show that an opinion is important, powerful, and hard to set aside

V. Rehabilitation

VI. Judicial standards for deciding cause

VII. Preserving appellate options

The panel will consider these and other key issues:

  • Is Batson still followed?
  • In a federal civil trial, what are the permissible reasons to challenge jurors for cause?
  • What standards does a court apply when determining juror challenges?
  • What is an impartial juror, and what is the test for determining a lack of impartiality?
  • What phraseology makes it easier for a juror to admit "cause" than to deny it?
  • How can counsel make rehabilitation less likely?